Del Rosario vs. Ocampo-Ferrer

A co-equal court of concurrent jurisdiction cannot interfere with the execution proceedings or annul the acts of a sheriff enforcing a writ of execution issued by another co-equal court; the proper remedy to assail alleged procedural defects in execution proceedings is to file a motion before the court that issued the writ, and upon denial, to seek certiorari before a higher court, not to institute an independent action for annulment before another coordinate court.

Ocampo-Ferrer obtained a loan from Del Rosario secured by a parcel of land in Calauan, Laguna. Upon default, Del Rosario filed a collection suit before the Regional Trial Court of Las Piñas City, Branch 275. The parties entered into a compromise agreement approved by the court, whereby Ocampo-Ferrer bound herself to pay ₱1,200,000.00 by June 19, 2005, in exchange for the return of the owner's duplicate certificate of title upon payment. When Ocampo-Ferrer failed to satisfy the obligation, Del Rosario moved for execution. The sheriff levied upon a different property of Ocampo-Ferrer located in Las Piñas City (covered by TCT No. 30480), conducted a public auction where Del Rosario emerged as the highest bidder, and issued a Certificate of Sale.

• The Loan and Security: Sometime in February 2001, respondent Cristina Ocampo-Ferrer obtained a loan of ₱850,000.00 from petitioner Eldefonso G. Del Rosario, secured by a parcel of land situated in Calauan, Laguna covered by TCT No. T-165897.
• The Compromise Agreement: After Ocampo-Ferrer defaulted, Del Rosario filed a complaint for sum of money before the RTC of Las Piñas City, Branch 275 (Civil Case No. LP-03-0088). On December 8, 2004, the parties entered into a Compromise Agreement whereby Ocampo-Ferrer bound herself to pay ₱1,200,000.00 on or before June 19, 2005, and Del Rosario undertook to return the owner's duplicate copy of TCT No. T-165897 upon receipt of payment. The RTC-Las Piñas Br. 275 issued an Order dated December 10, 2004, adopting and approving the Compromise Agreement as its decision.
• Execution Proceedings: Ocampo-Ferrer failed to comply with the compromise judgment. Del Rosario moved for execution, which the RTC-Las Piñas Br. 275 granted in an Order dated December 16, 2005. After the issuance of the Writ of Execution, petitioner Sheriff Josefino R. Ortiz issued a Demand/Notice to Pay to Ocampo-Ferrer, which she failed to satisfy.
• The Levy and Sale: Sheriff Ortiz levied upon Ocampo-Ferrer's parcel of land located in Las Piñas City covered by TCT No. 30480 (a different property from the one securing the original loan) and scheduled a public auction. At the auction sale, Del Rosario emerged as the sole and highest bidder. A Certificate of Sale dated February 20, 2006 was issued in his favor.
• The Challenge: Ocampo-Ferrer filed a complaint before the RTC of Las Piñas City, Branch 198 (Civil Case No. LP-07-0037) seeking the annulment of the sheriff's sale and payment of damages. She alleged that Del Rosario and Sheriff Ortiz committed unlawful acts in enforcing the writ of execution in Civil Case No. LP-03-0088.

• Lack of Jurisdiction: Petitioners argued that the RTC-Las Piñas Br. 198 had no jurisdiction to entertain Civil Case No. LP-07-0037 because it sought to annul actions emanating from a lawful order of a co-equal court, namely RTC-Las Piñas Br. 275. They maintained that the doctrine of judicial stability or non-interference bars a court from interfering with the judgments or orders of a co-equal court of concurrent jurisdiction.
• Bar by Prior Judgment: Petitioners contended that the complaint was barred by the prior judgment in Civil Case No. LP-03-0088, which Ocampo-Ferrer never challenged.

• Procedural Defects in Execution: Respondent Ocampo-Ferrer claimed that the levy performed by Sheriff Ortiz on the property covered by TCT No. 30480 was procedurally defective. She argued that under Section 9, Rule 39 of the Rules of Court, the sheriff failed to give her the opportunity to exercise the option of immediately choosing which among her properties should be levied upon.
• Improper Sequence of Levy: Respondent maintained that assuming she was given the option but failed to exercise it, the sheriff should have first levied on her personal properties, and only if insufficient, could he levy on her real properties such as the one covered by TCT No. 30480.

• Jurisdiction of Co-Equal Court: Whether the Court of Appeals correctly held that the levy and consequent sale of the property covered by TCT No. 30480 is null and void, notwithstanding that the action to annul was filed before a co-equal court of the court that issued the writ of execution.

• Jurisdiction of Co-Equal Court: The petition was meritorious. The RTC-Las Piñas Br. 198 lacked jurisdiction to entertain a suit seeking to annul the acts of a sheriff enforcing a writ of execution issued by co-equal RTC-Las Piñas Br. 275. Under the doctrine of judicial stability or non-interference, no court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having the power to grant the relief sought. The court that acquires jurisdiction over the case and renders judgment therein has jurisdiction over its judgment, to the exclusion of all other coordinate courts, for its execution and over all incidents. The proper remedy to assail orders originating from the issuing court is to file an action before a higher court with authority to nullify such orders, such as a petition for certiorari under Rule 65 of the Rules of Court, and not before a co-equal body. The RTC-Las Piñas Br. 198 should have dismissed Civil Case No. LP-07-0037 on the ground of lack of jurisdiction, without prejudice to its re-filing in the appropriate court.

• Doctrine of Judicial Stability or Non-Interference — This doctrine provides that no court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having the power to grant the relief sought. The rationale is founded on the concept of jurisdiction: a court that acquires jurisdiction over the case and renders judgment therein has jurisdiction over its judgment, to the exclusion of all other coordinate courts, for its execution and over all incidents, and to control, in furtherance of justice, the conduct of ministerial officers acting in connection with this judgment. A case where an execution order has been issued is considered as still pending, so that all proceedings on the execution are still proceedings in the suit. The court which issued a writ of execution has the inherent power, for the advancement of justice, to correct errors of its ministerial officers and to control its own processes. Splitting of jurisdiction is obnoxious to the orderly administration of justice. The remedy against a court that violates the law in issuing a writ of execution is not resort to another co-equal body but to a higher court with authority to nullify the action of the issuing court through a petition for certiorari under Rule 65.

• "The doctrine of judicial stability or non-interference in the regular orders or judgments of a co-equal court is an elementary principle in the administration of justice: no court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having the power to grant the relief sought."
• "The rationale for the rule is founded on the concept of jurisdiction: a court that acquires jurisdiction over the case and renders judgment therein has jurisdiction over its judgment, to the exclusion of all other coordinate courts, for its execution and over all incidents, and to control, in furtherance of justice, the conduct of ministerial officers acting in connection with this judgment."
• "The remedy, however, is not the resort to another co-equal body but to a higher court with authority to nullify the action of the issuing court. This is precisely the judicial power that the 1987 Constitution, under Article VIII, Section 1, paragraph 2, speaks of and which this Court has operationalized through a petition for certiorari, under Rule 65 of the Rules of Court."
• "It is not a viable legal position to claim that a TRO against a writ of execution is issued against an erring sheriff, not against the issuing Judge. A TRO enjoining the enforceability of a writ addresses the writ itself, not merely the executing sheriff."

• Barroso v. Omelio, G.R. No. 194767, October 14, 2015 — Controlling precedent explaining the doctrine of judicial stability or non-interference; followed by the Court in holding that a co-equal court cannot interfere with execution proceedings of another court.
• The Heirs of the Late Spouses Laura Yadno & Pugsong Mat-an v. The Heirs of the Late Spouses Anchales, 697 Phil. 390 (2012) — Cited in Barroso v. Omelio regarding the doctrine of judicial stability.
• Cabili v. Balindong, 672 Phil. 398 (2011) — Cited in Barroso v. Omelio regarding the appropriate remedy being certiorari before a higher court, not interference by a co-equal court.

• Section 9, Rule 39, Rules of Court — Cited by the Court of Appeals regarding the manner of enforcing judgments for money (levy on personal properties first, option to choose property to levy). The Supreme Court noted this provision but did not rule on its application, finding instead that the RTC-Las Piñas Br. 198 lacked jurisdiction to entertain the case.
• Article VIII, Section 1, paragraph 2, 1987 Constitution — Cited regarding the judicial power to nullify actions of lower courts through certiorari under Rule 65.

Sereno, C.J., Leonardo-De Castro, Bersamin, and Caguioa, JJ.