Heirs of Mat-an vs. Heirs of Anchales

No court of concurrent or coordinate jurisdiction may interfere by injunction with the final judgment, execution, or orders of another such court; the power to open, modify, or vacate them belongs exclusively to the rendering court. Applied to a final 1987 money judgment already enforced by levy, auction sale, non-redemption, and titling orders, a separate injunction and damages suit seeking nullification was correctly dismissed for lack of jurisdiction.

Petitioners are the heirs of Spouses Laura Yadno and Pugsong Mat-an, and respondents are the heirs of Spouses Mauro and Elisa Anchales, each group having substituted their deceased predecessors in the litigation below. The underlying controversy concerned enforcement of a joint and several money award against several defendants, satisfied through levy and execution sale of Baguio-registered land titled in the name of co-defendant Orani Tacay. No extrinsic statutory or regulatory regime beyond ordinary rules on final judgments, execution, and jurisdiction of Regional Trial Courts as courts of concurrent jurisdiction is required to understand the dispute.

On December 1, 1982, Spouses Mauro and Elisa Anchales sued Spouses Augusto and Rosalia Yadno, Orani Tacay, and Spouses Laura Yadno and Pugsong Mat-an before the then Court of First Instance, Branch 9, now Regional Trial Court, Branch 46, of Urdaneta, Pangasinan, for ownership, delivery of possession, damages with preliminary injunction and attachment, docketed as Civil Case No. U-3882. The Spouses Mat-an and Orani did not file an Answer and were declared in default, as were the Spouses Yadno after ex-parte presentation was allowed; the Yadnos' motion for reconsideration of the default order was denied and the case submitted for decision. On September 14, 1987, the Urdaneta RTC declared the Anchales spouses absolute owners of the land in question, ordered the Yadno spouses to vacate and remove their standing house, ordered all five defendants jointly and severally to pay 400 cavans of palay for the last six years up to and including 1982 and 1983 until vacatur and delivery, plus P10,000.00 attorney's fees solidarily, denying other damages for lack of evidence.

The decision became final and executory, and a Writ of Execution issued on September 20, 1988. Thereafter the Urdaneta sheriff issued a Notice of Levy dated October 10, 1988 on property registered in Orani's name covered by TCT No. T-13845 of Baguio City, annotated on November 7, 1988. A public auction was held on November 14, 1988 at which Mauro Anchales emerged highest bidder. A Certificate of Sale dated December 20, 1988 was issued to him and registered on August 7, 1989, followed by a Sheriff's Final Certificate of Sale issued March 7, 1991 and annotated April 3, 1991.

Meanwhile, on February 10, 1989, the Spouses Mat-an filed before the Baguio RTC, Branch 7, an action for injunction and damages with prayer for preliminary injunction against the Spouses Anchales, Spouses Yadno, and the Urdaneta Provincial Sheriff, docketed as Civil Case No. 1651-R. According to the Spouses Mat-an, on December 16, 1988 the sheriff without authority indiscriminately levied and auctioned Orani's TCT No. 13845 property while saving the Yadno spouses' Dungon, Sison property under TCT No. T-88740. They further alleged Orani died on December 28, 1986, before the September 14, 1987 decision, so her property had become her heirs' estate with distinct personality not subject to levy. On April 13, 1990 the Baguio case was archived on joint motion pending a partition case involving the Yadno and Mat-an spouses.

On April 30, 1991 the Spouses Anchales moved before the Urdaneta RTC for issuance of title, obtaining an Order dated July 2, 1991 directing the Yadno spouses, Orani, and the Mat-an spouses to surrender the owner's duplicate of TCT No. T-13845 within 15 days. The Mat-an spouses' challenge to that Order was dismissed by the Supreme Court in a Resolution dated December 12, 1991. By Order dated May 20, 1994 the Urdaneta RTC authorized the Baguio Register of Deeds to cancel TCT No. T-13845 and issue a new duplicate in Mauro Anchales' name, followed by an Order dated June 14, 1994 directing annulment of Orani's title and issuance of a replacement to Mauro Anchales immediately; TCT No. 60513 was issued to Mauro Anchales on July 6, 1994.

On September 16, 1997 the Spouses Mat-an moved ex-parte to revive the Baguio injunction case, for admission of a supplemental complaint, and for substitution of the deceased Mauro and Elisa Anchales. In the Supplemental Complaint they assailed the levy and sale as illegal and the July 2, 1991, May 20, 1994, and June 14, 1994 Orders as void, claiming the Urdaneta decision was null as to Orani because she died before rendition without substitution of her intestate estate. The Baguio RTC revived the case on October 22, 1997, admitted the Supplemental Complaint on February 9, 1998, required an answer which defendants filed with counterclaim, and on January 3, 2002 dropped the Yadno spouses as defendants on plaintiffs' motion. Defendants then moved to dismiss on the ground that the Baguio RTC, as a coordinate court, had no jurisdiction to enjoin the Urdaneta RTC. The Baguio RTC found Orani's property belonged to her intestate estate whose only legal heirs were Lauro Yadno and Augusto Yadno, both defendants in U-3882; that no intestate proceedings placed the properties in custodia legis elsewhere; and that levy to satisfy the U-3882 judgment was within authority, with exclusive jurisdiction over execution in Branch 46, Urdaneta.

• Custodia Legis and Completed Sale: Petitioner argued that the Supplemental Complaint expressly alleged the property was no longer in custodia legis because it had already been sold at public auction, TCT No. T-13845 cancelled, and TCT No. 60513 issued to Mauro Anchales on July 6, 1994.
• Quieting of Title and Reconveyance: Petitioner maintained that the main action before the court a quo was for quieting of title, recovery of ownership, and reconveyance, to which the policy of judicial stability was inapplicable.
• Incidental Nullification Prayer: Petitioner argued that the prayer to declare TCT No. 60513 null and void ab initio and to restore TCT No. T-13845 was merely incidental to quieting of title, recovery, and reconveyance, so judicial stability did not bar the Baguio court.
• Void Urdaneta Orders and Forum Shopping: Petitioner maintained that the Urdaneta RTC's July 2, 1991, May 20, 1994, and June 14, 1994 Orders issued during pendency of the Baguio case were null and void ab initio for utter lack of jurisdiction and grave abuse of discretion, and that respondents violated judicial stability and the prohibition against forum shopping in securing them.

• Coordinate Jurisdiction and Proper Forum: Respondent countered that the Baguio RTC had no jurisdiction to enjoin the Urdaneta RTC as a court of coordinate jurisdiction, and that the proper remedy was an appropriate motion or pleading before RTC Branch 46, Urdaneta, which rendered the judgment.
• Unnotified Death and Fault: Respondent argued that petitioners' predecessors never informed the Urdaneta trial court of Orani Tacay's alleged death, as pointed out in the Answers to the original and supplemental complaints, and that such omission was petitioners' fault and was never rebutted in the Baguio case or in rejoinder.

• Jurisdiction – Interference by Coordinate Court: Whether the Baguio RTC correctly dismissed for lack of jurisdiction the injunction and damages suit seeking nullification of the final Urdaneta RTC judgment, levy and execution sale, and subsequent titling orders.

• Jurisdiction – Interference by Coordinate Court: No. Dismissal was correct. A final judgment and its execution processes under a court of competent jurisdiction cannot be nullified or enjoined by another RTC of concurrent jurisdiction, whose power is restricted to the rendering court.

• Jurisdiction – Interference by Coordinate Court: The September 14, 1987 Urdaneta decision had long become final and executory, adjudging Orani among those jointly and severally liable for 400 cavans of palay, and its enforcement by October 10, 1988 levy, November 14, 1988 auction to Mauro Anchales, registration of the December 20, 1988 certificate of sale, and unredeemed ripening into absolute sale was documented on TCT No. 13845. Because the July 2, 1991 surrender order and the May 20, 1994 and June 14, 1994 cancellation and reissuance orders culminating in TCT No. 60513 on July 6, 1994 were merely consequences of that executed judgment, a Baguio injunction suit attacking them as void attacked the final judgment itself. The death-without-substitution theory belonged before the rendering Urdaneta court, which had never been notified of Orani's alleged December 28, 1986 death, and petitioners' predecessors — with Laura Yadno and Augusto Yadno as Orani's admitted heirs and themselves judgment debtors — could not use concealment followed by collateral attack without inviting endless litigation. Nor did completed titling remove the bar, since the property had been in custodia legis of Urdaneta when levied and sold under its writ and the new title derived from that unredeemed execution sale; likewise, the complaint's own allegations showed its substance was nullification of the judgment, levy, sale, and new title, not an independent quieting, recovery, or reconveyance action, leaving general supervisory control over execution with Urdaneta to resolve every factual and legal question involved.

• Judicial stability / non-interference by courts of concurrent jurisdiction — No court has the power to interfere by injunction with the judgments, decrees, or orders of a court of concurrent or coordinate jurisdiction; the various trial courts of equal authority cannot interfere with each other's cases, orders, or judgments, and the power to open, modify, or vacate belongs exclusively to the rendering court. Applied to bar the Baguio RTC from nullifying the final Urdaneta RTC decision and its levy, sale, and titling orders through an injunction and damages action.
• Supervisory control over execution — The court rendering the judgment has general supervisory control over its processes in execution, with the right to determine every question of fact and law involved in execution. Applied to hold that challenges to the validity of the judgment as against Orani, the levy on TCT No. 13845, the auction, and the post-sale orders should have been raised before the Urdaneta RTC, Branch 46.
• Custodia legis in execution sale — Property levied under a lawful writ for satisfaction of judgment is placed under the custody of the executing court, beyond the authority of a co-equal court, and a subsequent title issued after failure to redeem derives from that levy and sale. Applied to reject the claim that issuance of TCT No. 60513 removed the property from Urdaneta's custody and conferred jurisdiction on Baguio.

• "The long standing doctrine is that no court has the power to interfere by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction." — States the controlling non-interference rule that required dismissal of the Baguio injunction suit attacking the Urdaneta judgment.
• "the power to open, modify or vacate the said judgment or order is not only possessed by but is restricted to the court in which the judgment or order is rendered or issued." — Defines why only the Urdaneta RTC could resolve the alleged nullity from death without substitution and the validity of execution.
• "A contrary rule would obviously lead to confusion and seriously hamper the administration of justice." — Gives the policy justification for prohibiting co-equal courts from enjoining each other's judgments and orders.
• "It is the Urdaneta RTC which has a general supervisory control over its processes in the execution of its judgment with a right to determine every question of fact and law which may be involved in the execution." — Articulates the execution-jurisdiction basis for requiring all levy, sale, and titling challenges to be litigated in Urdaneta.

• Tiu vs. First Plywood Corporation, G.R. Nos. 176123 and 185264, March 10, 2010, 615 SCRA 117 — Cited as authority that a judgment of a court of competent jurisdiction may not be interfered with by a concurrent court and that the controversy should be settled by the rendering court.
• Philippine Commercial International Bank vs. Court of Appeals, G.R. No. 114951, July 17, 2003, 406 SCRA 575 — Cited through Tiu for the principle restricting the power to open, modify, or vacate to the rendering court.
• Ching vs. Court of Appeals, G.R. No. 118830, February 24, 2003, 398 SCRA 88 — Cited for the rule that trial courts of equal authority cannot interfere with each other's orders or judgments and that the contrary rule hampers justice.
• Crystal vs. Court of Appeals, No. L-35767, April 15, 1988, 160 SCRA 79 — Cited through Tiu for requiring the whole controversy over execution to be settled by the rendering court.
• Heirs of Elias Lorilla vs. Court of Appeals, G.R. No. 118655, April 12, 2000, 330 SCRA 429 — Cited to warn against concealing a party's death, proceeding through trial, then collaterally attacking the judgment for non-substitution.
• Paper Industries Corp. of the Philippines vs. Intermediate Appellate Court, G.R. No. L-71365, June 18, 1987, 151 SCRA 161 — Cited for the rendering court's general supervisory control over execution and power to decide questions involved therein.

Presbitero J. Velasco, Jr., Chairperson, Roberto A. Abad, Jose Portugal Perez, Jose Catral Mendoza. No separate concurring reasoning beyond joinder is shown in the text.