The Supreme Court has firmly established that no court can interfere with the judgments or orders of another court with concurrent jurisdiction. This principle ensures that once a court of competent jurisdiction has made a ruling, other courts cannot modify or vacate that decision. This doctrine prevents conflicts and maintains the integrity of the judicial process.

The Battle for Authority: When One Court’s Order Intrudes on Another’s Turf

This case, Jimmy T. Go v. The Clerk of Court, arose from a collection suit filed by Multi-Luck Corporation against Alberto T. Looyuko. Multi-Luck sought to execute a judgment against Looyuko’s properties. Jimmy T. Go, claiming to be a co-owner of these properties, filed an injunction in a different court to stop the execution. The central legal question was whether the second court had the authority to interfere with the execution order of the first court, which had already rendered judgment.

The factual backdrop is that Multi-Luck Corporation initiated a collection suit against Alberto T. Looyuko, doing business as Noah’s Ark Merchandising Inc. (NAMI), for dishonored checks amounting to P8,985,440.00. The Regional Trial Court (RTC) of Bacolod City ruled in favor of Multi-Luck, and when Looyuko/NAMI failed to appeal, the decision became final. Multi-Luck then sought a writ of execution to seize Looyuko’s assets, including a house and lot and shares in a golf club. Jimmy T. Go, claiming a co-ownership in Looyuko’s properties, filed an injunction case in the RTC of Pasig City to halt the auction. Go argued that as a co-owner, the execution would unlawfully deprive him of his property without due process, as he was not a party to the original collection suit. The Pasig RTC initially granted a temporary restraining order and later a writ of preliminary injunction, preventing the auction.

Multi-Luck moved to dismiss the injunction case, asserting that the Pasig RTC lacked jurisdiction over the matter and the involved sheriffs and Multi-Luck itself. The Pasig RTC denied this motion, leading Multi-Luck to appeal to the Court of Appeals (CA). The CA reversed the Pasig RTC’s decision, holding that it had improperly interfered with the Bacolod RTC’s order. The CA emphasized that the Bacolod RTC, as a court of concurrent jurisdiction, had the authority to execute its judgment without interference from another court. The Supreme Court affirmed the CA’s ruling, reinforcing the principle of non-interference between courts of concurrent jurisdiction. This doctrine ensures that once a court has jurisdiction over a case, it retains that jurisdiction until the matter is fully resolved, including the execution of its judgment.

The Supreme Court reiterated the well-established doctrine that no court can interfere with the judgments or orders of another court of concurrent jurisdiction. This principle is rooted in the idea that a judgment from a competent court should not be opened, modified, or vacated by another court with similar authority. The Court emphasized that execution proceedings are a continuation of the original suit. Since the Bacolod RTC had already acquired jurisdiction over the collection suit and rendered judgment, it retained exclusive jurisdiction over all matters related to that judgment, including the actions of its officers, such as the sheriffs. Therefore, the Pasig RTC’s issuance of the injunction was a clear intrusion into the Bacolod RTC’s authority.

The petitioner, Jimmy T. Go, argued that he should be considered a third-party claimant under Rule 39, Section 16 of the Rules of Court, which would allow him to protect his property from execution. He claimed that the judgment against Looyuko/NAMI should not bind him or his properties since he was not a party to the original case. However, the Supreme Court rejected this argument, distinguishing the case from previous rulings where such intervention was allowed. The Court clarified that the Bacolod RTC had the jurisdiction to resolve the question of Go’s ownership had he properly filed his claim with that court. The Supreme Court noted that any questions regarding the execution of the decision should be addressed within the original case in the Bacolod RTC.

Go’s claim of co-ownership was based on agreements dated February 9, 1982, and October 10, 1986, which purportedly established his partnership with Looyuko in NAMI. The February 9, 1982 agreement stated that Go was entitled to 50% of the business’s assets, while the October 10, 1986 agreement specified that profits and losses from Noah’s Ark Merchandising would be equally divided. However, the Court noted that the authenticity and due execution of these documents were under litigation in separate proceedings. Furthermore, NAMI had operated as a registered single proprietorship under Looyuko for over two decades. The Court of Appeals observed that even if the partnership agreements were valid, NAMI was legally recognized as a single proprietorship, and third parties dealing with it, like Multi-Luck, had the right to rely on Looyuko’s personal liability for the business’s debts. The appellate court further noted that Go had not taken steps to register NAMI as a partnership, which would have protected his interests.

Building on this point, the Supreme Court found that Go was estopped from disavowing NAMI’s status as a single proprietorship and claiming co-ownership. The attached real properties were registered solely in the names of Looyuko and NAMI. Go’s attempt to assert his claim through an affidavit of adverse claim, which he had annotated on the property title, was deemed insufficient. The Court emphasized that under Section 70 of P.D. 1529, an adverse claim is only effective for thirty days unless a corresponding action is filed. Since Go did not file such an action before the properties were attached, Looyuko and/or NAMI remained the sole owners at the time of the execution order. The Supreme Court reiterated that once a decision becomes final and executory, the presiding judge has a ministerial duty to issue a writ of execution, unless subsequent events render such execution unjust, which was not the case here.

In conclusion, the Supreme Court affirmed the principle that courts of concurrent jurisdiction should not interfere with each other’s judgments. This ruling underscores the importance of respecting the judicial process and ensuring that judgments are executed without undue obstruction from other courts. The Court’s decision reinforces the stability and predictability of the legal system, preventing parties from forum shopping or attempting to undermine valid court orders through collateral actions.

FAQs

What was the key issue in this case?	The key issue was whether a court could issue an injunction to restrain the execution of a judgment by another court of concurrent jurisdiction. The Supreme Court ruled that such interference is not allowed.
What is the principle of non-interference between courts?	The principle of non-interference states that no court has the power to interfere with the judgments or orders of another court of concurrent jurisdiction. This prevents conflicting rulings and maintains judicial order.
Who was Jimmy T. Go in this case?	Jimmy T. Go claimed to be a co-owner of the properties being executed upon. He sought an injunction to prevent the sale of these properties, arguing that he was not a party to the original collection suit.
Why did the Supreme Court deny Jimmy T. Go’s petition?	The Supreme Court denied the petition because the Pasig RTC’s injunction interfered with the Bacolod RTC’s judgment. Additionally, Go failed to prove a clear legal right to the properties in question.
What is an adverse claim, and how did it relate to this case?	An adverse claim is a notice registered on a property title indicating that someone claims an interest in the property. In this case, Go’s adverse claim was deemed ineffective because he did not file a corresponding action within the prescribed period.
What is the significance of NAMI being a single proprietorship?	The fact that NAMI was a registered single proprietorship meant that Alberto T. Looyuko was personally liable for its debts. This also meant that third parties could rely on Looyuko’s ownership and responsibility for NAMI’s obligations.
What are the grounds for issuing a preliminary injunction?	A preliminary injunction may be granted when the applicant is entitled to the relief demanded, the act complained of would cause injustice, or a party is violating the applicant’s rights. A clear and positive right must be shown.
What was the effect of the agreements presented by Jimmy T. Go?	The agreements, which purportedly established Go’s partnership with Looyuko, were under litigation regarding their authenticity. Moreover, they did not override the fact that NAMI was a registered single proprietorship, which third parties could rely upon.
What is the role of a writ of execution?	A writ of execution is a court order directing a law enforcement officer to enforce a judgment by seizing and selling the judgment debtor’s property. Once a decision is final, issuing a writ of execution is a ministerial duty of the court.

This case clarifies the jurisdictional boundaries between courts and reinforces the principle that final judgments must be respected and enforced without undue interference. Understanding these principles is crucial for navigating legal disputes and ensuring the integrity of the judicial process.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Jimmy T. Go v. The Clerk of Court, G.R. No. 154623, March 13, 2009