LUALHATI A. COJUANGCO v. PURIFICACION VILLEGAS

FACTS:

The case revolves around a residential land in Malolos, Bulacan. Villegas' parents built a house and a bakery on the land with the consent of the registered owner, Cojuangco. Villegas and her predecessors-in-interest occupied the property for over sixty years, without paying rent, as long as they vacated when needed by the owner. However, Villegas later leased out a portion of the land without Cojuangco's knowledge. As a result, Cojuangco demanded that Villegas leave the property, but she refused. Consequently, Cojuangco initiated an ejectment case against Villegas, which was initially dismissed by the trial court for lack of jurisdiction. However, on appeal, the court overturned the decision and ordered Villegas to vacate the premises. This ruling was subsequently affirmed by the appellate court and the Supreme Court.

After the judgment became final, Cojuangco sought the execution of the judgment and filed a motion for execution, which the trial court granted. However, before the eviction could be carried out, Villegas filed a separate civil action for specific performance, seeking to halt the execution of the judgment. The case landed in a different branch of the trial court, which issued both a temporary restraining order and a preliminary injunction against Cojuangco and the sheriff. Cojuangco argues that these orders amount to interference with the final and executory decision of another court, which is not permitted under the principle of judicial hierarchy.

ISSUES:

  1. Whether or not the execution of a final judgment in an ejectment case may be stayed by a co-equal court in order to protect the right of indemnification and retention of an alleged builder in good faith.

  2. Whether or not the respondent court's issuance of temporary restraining order and preliminary injunction amounts to grave abuse of discretion.

RULING:

  1. No, the execution of a final judgment in an ejectment case may not be stayed by a co-equal court to protect the right of indemnification and retention of an alleged builder in good faith. The interference of one court with the judgments or decrees of a court with concurrent or coordinate jurisdiction is not allowed.

  2. Yes, the respondent court's issuance of temporary restraining order and preliminary injunction amounts to grave abuse of discretion. The court's interference with a final and executory decision of a co-equal court is not permissible.

PRINCIPLES:

  • No court has the power to interfere by injunction with the judgments or decrees of a court with concurrent or coordinate jurisdiction.

  • Interference of one court with the final and executory decision of a co-equal court is anathema in the judicial system.