G.R. No. L-77526. June 29, 1988. VICENTE VER, ET AL., petitioners, vs. PRIMO QUETULIO, SUBSTITUTED BY DOMINICA Q. HERNANDO AND BRANCH XIII, REGIONAL TRIAL COURT OF ILOCOS NORTE, respondents.
FACTS:

Private respondent Primo Quetulio filed a complaint to quiet title over sixteen parcels of land, claiming ownership via a 1929 Deed of Sale from Mercedes Ver. Petitioners, heirs of the original owner Leon Ver, contested the sale, asserting the properties were part of the undivided estate of Leon Ver, administered by Mercedes Ver for all co-heirs, and thus could not be validly sold without their consent. The then Court of First Instance declared the sale void and recognized the properties as common and undivided property of the heirs, ordering Quetulio to restore possession and pay damages. Quetulio appealed to the Supreme Court (G.R. No. L-6831), which in 1956 affirmed the sale’s nullity but remanded the case for proper partition and accounting of fruits received by the heirs.
Subsequently, the Intermediate Appellate Court (IAC) in AC-G.R. No. CV-00206 issued a 1984 decision, later amended in 1985, which petitioners argue effectively reversed the final 1956 Supreme Court ruling by validating Quetulio’s title and awarding him damages. The Regional Trial Court (RTC) issued orders in 1987 directing execution of this IAC decision, leading the provincial sheriff to levy and sell the heirs’ properties at auction to satisfy the damages award.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in ordering the execution of the Intermediate Appellate Court’s decision, which allegedly modified a final and executory Supreme Court decision.

RULING

Yes. The Supreme Court granted the petition and set aside the RTC’s orders. The legal logic is anchored on the doctrine of finality of judgments and the hierarchical authority of judicial decisions. The Supreme Court’s 1956 decision in G.R. No. L-6831, which declared the deed of sale void and remanded the case for partition, had long become final and executory. A final judgment cannot be amended or substantially modified by a lower court. The Intermediate Appellate Court, in its 1984/1985 decision, overstepped its authority by effectively altering this final Supreme Court ruling. Its decision was therefore null and void for lack of jurisdiction. Consequently, any writ of execution issued by the RTC based on this void appellate decision is itself invalid. The auction sale conducted to enforce this void judgment is likewise null and void. The Supreme Court permanently enjoined the provincial sheriff from executing a final deed of sale to the auction winner and remanded the case to the lower court for proceedings consistent with the 1956 Supreme Court decision.