G.R. No. 15697 - People vs Singson

In National Power Corporation v. Alonzo-Legasto, the Court awarded First United Constructors Corporation (FUCC) the sum of P74,035,503.50 plus legal interest.
The award was determined as just compensation for the blasting work performed by FUCC under its contract with the National Power Corporation (NPC) for the construction of power facilities.
The decision became final and executory on January 4, 2005.

FUCC filed a motion with the RTC, Branch 99, Quezon City, for the appointment of a new implementing sheriff to carry out the execution of the judgment.
Engr. Ernesto G. Bautista of Dynamic Blasting Specialist of the Philippines, not initially a party to the case, filed a motion requesting the court to direct the branch sheriff to release P37,723,823.00 (plus interest) allegedly due to him.
During the hearing, FUCC objected to Bautista’s participation, arguing that Bautista lacked the necessary personality as he was not a formal party to the case.
Despite FUCC’s objections, the trial court (RTC, Branch 99) held that it possessed jurisdiction to resolve Bautista’s claim, citing precedents that allowed non-parties to intervene for the sake of substantial justice.
The trial court ruled that because both FUCC and NPC recognized Bautista as a subcontractor for the blasting work, Bautista was bound by the final decision in National Power Corporation v. Alonzo-Legasto.
Consequently, the trial court granted Bautista’s motion, directing that:

The money claims of both FUCC and Bautista be satisfied through the funds of NPC deposited with the Land Bank of the Philippines.
The amount of P37,723,823.00 due Bautista be deducted from FUCC’s awarded amount.

An Alias Writ of Execution was issued on July 29, 2005 pursuant to the trial court’s order.

FUCC filed an urgent motion for the issuance of a Temporary Restraining Order (TRO) on August 8, 2005, aiming to freeze the implementation of the trial court’s order.
The Court, after a status quo order was issued enjoining further action, later granted FUCC’s Motion for Leave to Withdraw the urgent TRO motion.
FUCC then sought the annulment of the trial court’s Order dated July 18, 2005, contending that the order had improperly altered the final judgment of National Power Corporation v. Alonzo-Legasto.
The RTC, Branch 76, Quezon City, denied FUCC’s motion on the basis that a judge from one branch could not annul an order of another branch, and that the questioned order had attained finality.

FUCC raised its controversy before the Court of Appeals (CA) through a petition for certiorari and prohibition, challenging:

The validity of the RTC orders (dated July 18, 2005 and March 8, 2006) and the Alias Writ of Execution (dated July 29, 2005).
The refusal to issue a TRO that would have preserved the status quo and protected its awarded sum.

The Appellate Court denied the TRO on the ground that the subsequent status quo order (August 8, 2005) had dissolved the earlier injunction, thereby rendering the trial court’s orders enforceable.
Additional interventions and comments were made:

Bautista eventually filed separate pleadings for specific performance with damages against FUCC, NPC, and the Land Bank.
The Office of the Solicitor General (OSG) argued against the issuance of an injunctive writ, citing forum-shopping and the non-compliance with the procedural requirement under Presidential Decree No. 1445 for claims against the government.

Whether the Court of Appeals committed grave abuse of discretion in refusing to issue the Temporary Restraining Order (TRO) sought by FUCC.

Whether the trial court’s orders (dated July 18, 2005 and March 8, 2006) and the Alias Writ of Execution (dated July 29, 2005) validly altered or modified the final decision in National Power Corporation v. Alonzo-Legasto.
Whether it is proper for a judge from one branch of the same court to annul or modify an order of another branch.
The propriety of allowing a non-party (Bautista) to intervene and assert a claim that effectively reduces the awarded judgment meant for FUCC.
Whether the withdrawal of FUCC’s urgent TRO motion and the subsequent status quo order should have led to an independent evaluation by the appellate court rather than a perfunctory denial of the TRO.