The Supreme Court retains jurisdiction to control and supervise the execution of its final and executory judgments to prevent injustice or when supervening events transpire that may render execution unjust or impossible; the issuance of a temporary restraining order on an execution is a valid exercise of judicial power and does not usurp executive or legislative prerogatives, but such a TRO may be lifted when the circumstances justifying its issuance no longer exist.

Petitioner Leo Echegaray was sentenced to death, a conviction affirmed by the Supreme Court in G.R. No. 117472. Subsequently, in G.R. No. 132601, Echegaray challenged the constitutionality of Republic Act No. 8177 (Lethal Injection Law) and its implementing rules. While the Court upheld R.A. No. 8177, it invalidated certain sections of its implementing rules, which were later amended. As Echegaray's execution neared, he filed a Very Urgent Motion for a TRO, citing potential moves in Congress to review or repeal the death penalty law. The Supreme Court, in a Special Session on January 4, 1999, issued a TRO temporarily suspending his execution until June 15, 1999, to allow Congress time to deliberate on the matter. The public respondents then filed an Urgent Motion for Reconsideration of this TRO.

• The Supreme Court's decision in G.R. No. 132601, upholding R.A. No. 8177 but invalidating parts of its IRR, became final and executory on November 6, 1998.
• Petitioner Leo Echegaray was scheduled for execution. On December 28, 1998, he filed a Very Urgent Motion for a TRO, alleging moves in Congress to review or repeal the death penalty law.
• On January 4, 1999, the Court issued a TRO suspending the execution until June 15, 1999, to allow Congress time to consider repealing or modifying the death penalty law, citing the need for caution when life is at stake.
• Public respondents filed an Urgent Motion for Reconsideration, arguing the Court lost jurisdiction, the TRO trenched on executive authority, and supervening events showed no likelihood of legislative repeal.
• Supervening events cited by respondents included: (a) President Estrada's pronouncement to veto any repeal of the death penalty for heinous crimes; (b) a House Resolution by Congressman Golez against repeal, concurred in by 113 congressmen; and (c) Senator Roco's repeal resolution having only two signatories.
• The House of Representatives formally adopted a resolution (House Resolution No. 25) expressing no desire to review R.A. No. 7659 at that time.

• The issuance of the TRO was within the scope of judicial power and duty, and did not trench on executive or congressional prerogatives.
• The Court's exercise of its power to stay execution was reasonable, given the possibility of legislative repeal or modification of the death penalty law.
• The Court did not lose jurisdiction to address incidental matters arising from the petition, even after the judgment became final.
• Public respondents were estopped from challenging the Court's jurisdiction, especially since the Secretary of Justice had previously sought relief from the Court regarding the execution.
• There was no certainty that the death penalty law would not be repealed or modified until Congress convened and considered various bills.

• The decision in the case having become final and executory, its execution entered the exclusive ambit of executive authority, and the TRO trenched on this sphere.
• The TRO created a dangerous precedent, potentially leading to endless litigation due to the ever-present possibility of legislative repeal.
• Congress had already deliberated extensively on the death penalty, and any questions were likely already debated.
• The Court, by issuing the TRO, transcended its power of judicial review under the maxim lex futuro, judex praeterito (the law looks forward, the judge looks at the past).
• Supervening events indicated that the repeal or modification of the death penalty law was highly unlikely (President's veto threat, House Resolution against repeal, limited support for Senate repeal resolution).

• Whether the Supreme Court lost jurisdiction to restrain the execution of the petitioner after its decision in G.R. No. 132601 became final and executory.
• Whether the issuance of the TRO by the Supreme Court trenched upon the sphere of executive authority, specifically the President's power to grant reprieve.
• Whether the TRO issued on January 4, 1999, should be lifted in light of supervening events indicating no congressional intent to repeal or amend the death penalty law.

• The Supreme Court did not lose jurisdiction over the case. While a final judgment cannot be amended, modified, or altered, the Court retains jurisdiction to execute and enforce the judgment. The Court has inherent power to control the execution of its decisions, especially when supervening events may render execution unjust or impossible.
• The issuance of the TRO did not trench on the executive's power of reprieve. The power of courts to control the enforcement of their decisions, including suspending execution in certain circumstances (e.g., insanity of convict), is a judicial function. The powers of the Executive, Legislative, and Judiciary to save a life are not mutually exclusive.
• The TRO issued on January 4, 1999, should be lifted. The TRO was issued cautiously to allow Congress time to consider repealing or modifying the death penalty law, as alleged by the petitioner. However, subsequent events, including a House Resolution against reviewing the death penalty law and the President's stance, demonstrated that the possibility of legislative repeal or modification within the TRO's timeframe had become nil. The TRO having served its legal and humanitarian purpose of crystallizing the issue of congressional disposition, it was lifted.

• Finality of Judgment — A judgment that has become final and executory can no longer be amended, modified, or altered by the court. However, the court retains jurisdiction to execute and enforce such judgment. The Court explained that finality divests the court of jurisdiction to change the judgment, but not its power to ensure its proper execution, especially if supervening events render execution unjust.
• Judicial Power over Execution of Judgments — Courts have inherent and necessary power to control and supervise the process of execution of their decisions. This power continues even after the judgment has become final. The Court asserted this power as essential to its jurisdiction, allowing it to intervene when supervening events affect the fairness of execution.
• Separation of Powers — The principle that the powers of government are divided among co-equal branches (executive, legislative, judiciary), each supreme within its own sphere. The Court ruled that its temporary restraint of execution was a judicial act and not an encroachment on the President's power of reprieve, nor did it restrain the effectivity of a law enacted by Congress but rather the execution of its own decision pending clarification of legislative intent.
• Rule-Making Power of the Supreme Court — The exclusive authority of the Supreme Court to promulgate rules concerning pleading, practice, and procedure in all courts. The Court traced the evolution of this power under the 1935, 1973, and 1987 Constitutions, highlighting that the 1987 Constitution removed Congress's power to repeal, alter, or supplement these rules, thereby strengthening judicial independence and affirming the Court's authority over execution procedures.
• Estoppel — A legal principle that prevents a party from asserting something contrary to what is established by their own conduct or previous statement. The Court noted that the public respondents were estopped from challenging its jurisdiction over the execution process because the Secretary of Justice had previously invoked the Court's jurisdiction by filing a motion to compel the trial judge concerning the execution date.
• Supervening Events — Facts and circumstances that transpire after a judgment has become final, which can render the execution of the judgment unjust or impossible. The Court lifted the TRO because supervening events (crystallization of Congressional intent not to repeal the death penalty law) negated the basis for its issuance.
• Judicial Comity — Respect accorded by one court or branch of government to the proceedings or decisions of another. Justice Vitug, in his separate opinion, mentioned that the TRO was issued principally out of respect and comity to Congress to allow it an opportunity to re-examine the death penalty law.

• "the finality of a judgment does not mean that the Court has lost all its powers nor the case. By the finality of the judgment, what the court loses is its jurisdiction to amend, modify or alter the same. Even after the judgment has become final the court retains its jurisdiction to execute and enforce it."
• "The power to control the execution of its decision is an essential aspect of jurisdiction. It cannot be the subject of substantial subtraction for our Constitution vests the entirety of judicial power in one Supreme Court and in such lower courts as may be estabished by law."
• "The powers of the Executive, the Legislative and the Judiciary to save the life of a death convict do not exclude each other for the simple reason that there is no higher right than the right to life."
• "any error of the Court in not stopping the execution of the petitioner will preclude any further relief for all rights stop at the graveyard."
• "The flame of the rule of law cannot be ignited by rage, especially the rage of the mob which is the mother of unfairness. The business of courts in rendering justice is to be fair and they can pass their litmus test only when they can be fair to him who is momentarily the most hated by society."

• Director of Prisons v. Judge of First Instance (29 Phil. 267) — Cited to establish the principle that courts retain control over the execution of sentences, including capital punishment, and can postpone execution if circumstances warrant, even after the judgment is final. This case supports the Court's power to investigate emergencies and order postponement of execution.
• In re Cunanan (94 Phil. 534) — Referenced to illustrate the Supreme Court's power over the admission to the practice of law and its ability to strike down legislative acts encroaching on this judicial power, even under the 1935 Constitution where Congress had some power to amend court rules. This was used to argue the strength of the Court's rule-making power.
• Legaspi v. Civil Service Commission (150 SCRA 530) — Cited in the context of the Secretary of Justice's argument regarding the right to information, specifically that the right to information provision is self-executing.
• People v. Vera (65 Phil. 56) — Mentioned in the context of the President's power to grant reprieve, defining reprieve as postponing the execution of a sentence to a day certain.

• 1987 Constitution, Article VIII, Section 5(5) — Vests in the Supreme Court the power to promulgate rules concerning the protection and enforcement of constitutional rights, pleading, practice, and procedure in all courts. Cited to emphasize the Court's expanded and exclusive rule-making power, which includes rules on execution of judgments, free from congressional repeal or alteration.
• 1987 Constitution, Article VII, Section 19 — Grants the President the power to grant reprieves, commutations, and pardons. Cited by respondents to argue that execution falls under exclusive executive authority, an argument the Court rejected by stating this provision does not deny courts power over their own decisions' enforcement.
• 1987 Constitution, Article III, Section 7 (Bill of Rights - Right to Information) — Guarantees the right of the people to information on matters of public concern. Cited by the Secretary of Justice in a prior motion (unrelated to the TRO's merits but showing his invocation of Court's jurisdiction) regarding the disclosure of the execution date.
• 1987 Constitution, Article II, Section 28 (Declaration of Principles and State Policies - Full Public Disclosure) — States the policy of full public disclosure of all transactions involving public interest. Also cited by the Secretary of Justice in the prior motion.
• Rule 135, Section 6, Rules of Court — Provides that when jurisdiction is conferred on a court, all auxiliary writs, processes, and other means necessary to carry it into effect may be employed. Cited to support the Court's inherent power to control its processes and orders to make them conformable to law and justice, including the execution of its decisions.
• Republic Act No. 8177 (Lethal Injection Law) — The law whose constitutionality was challenged in G.R. No. 132601. The finality of the decision upholding this law (while striking down parts of its IRR) is a precursor to the execution being restrained.
• Republic Act No. 7659 (Death Penalty Law) — The law re-imposing the death penalty. The TRO was issued based on potential congressional review of this law. The subsequent House Resolution not to review R.A. 7659 was a key factor in lifting the TRO.
• Article 83 of the Revised Penal Code (as amended by Section 25 of Republic Act No. 7659) — Referenced in the original decision of G.R. No. 132601 as being contravened by Section 17 of the IRR of R.A. No. 8177.
• Article 81 of the Revised Penal Code — Provides that the death sentence shall be carried out without prejudice to the President's executive clemency powers. Cited by the Secretary of Justice in a prior motion.

• Justice Panganiban — Voted to deny the Solicitor General's Motion for Reconsideration. He maintained his view that R.A. 7659 (Death Penalty Law) is unconstitutional in parts for failing to meet constitutional requirements of "heinousness" and "compelling reasons," and that R.A. 8177 (Lethal Injection Law) is likewise unconstitutional as it implements an unconstitutional law. Therefore, he could not vote to lift the TRO as it would mean upholding and enforcing a law he believes is unconstitutional. However, he stressed deference to the rule of law and the Court's majority ruling.
• Justice Vitug — Voted against the lifting of the restraining order. He reiterated his stance that R.A. No. 7659, prescribing the death penalty, falls short of the strict constitutional norm. While acknowledging the Court's jurisdiction to issue and manage the TRO (initially issued out of comity to Congress), he believed the exacting standards of the Constitution for imposing the death penalty were not met by the current structure of R.A. No. 7659. He expressed hope for a future dispassionate re-examination of the law by Congress but, pending that, dissented from lifting the TRO.