G.R. No. 146006 - Lee vs. Regional Trial Court of Quezon City, Branch 85

The litigation originated from a petition for letters of administration of the intestate estate of Dr. Juvencio P. OrtaAez filed on September 24, 1980.
The estate included 2,029 shares of stock in Philippine International Life Insurance Company (Philinterlife).
Petitioners are Jose C. Lee and Alma Aggabao, acting in their capacities as president and corporate secretary of Philinterlife, in conjunction with the Filipino Loan Assistance Group (FLAG).
Private respondent, Ma. Divina OrtaAez-Enderes, an illegitimate child of the decedent, assumed the role of special administratrix over the 2,029 shares.

During the pendency of the estate proceedings, legitimate family members (Juliana, Jose, and Rafael OrtaAez) executed an extrajudicial settlement partitioning the estate, which included the Philinterlife shares.
Subsequently, Juliana and Jose sold the 2,029 shares to FLAG despite the unresolved status of the estate.
Concurrently, the appointment of Ma. Divina OrtaAez-Enderes as special administratrix situating her as the custodian of the shares further complicated the matter.

Upon filing an omnibus motion to approve the sale and release the special administratrix, Jose OrtaAez encountered a denial by the trial court on August 11, 1997.
The trial court later declared, on August 29, 1997, that the extrajudicial settlement was partially void ab initio as it pertained to the transfer of the Philinterlife shares.
Both the Court of Appeals and the Supreme Court subsequently upheld these orders.
On July 6, 2000, the trial (intestate) court issued a writ of execution confirming:

The nullity of the sale of the 2,029 shares to FLAG.
The reinstatement of the shares in the stock and transfer book in favor of the estate.
The issuance of stock certificates in the name of the estate.
The exclusive right of the special administratrix to exercise all attendant rights on the shares.
The mandatory compliance by Philinterlife officers within three days under pain of contempt, with deputy sheriffs empowered to enforce the order.

Petitioners resisted the enforcement of the writ of execution.
They filed a petition for certiorari with the Court of Appeals (CA G.R. SP No. 59736) challenging the writ, which was dismissed outright on July 26, 2000.
The Supreme Court, in its February 23, 2004 decision, affirmed the dismissal of petitioners’ petition, thereby reinforcing the orders of the lower courts.

The February 23, 2004 decision became final and executory on July 9, 2004.
An alias writ of execution was issued by the intestate court on October 1, 2004; however, petitioners filed a motion on October 15, 2004 to suspend execution on the grounds of supervening events.
Petitioners’ arguments included claims that:

The appointment of the special administratrix had been revoked by prior orders.
Proper legal procedure needed to be observed regarding the implementation of the writ.
The share price valuation issues warranted reconsideration of the directives.

Private respondent countered that these arguments were mere attempts to impede the execution of the final and executory decisions and filed an omnibus motion for indirect contempt against petitioners and disciplinary sanctions against petitioners’ counsel.

Petitioners’ counsel, Atty. Teodorico Fernandez, came under scrutiny due to efforts perceived as a mockery of judicial processes.
The Supreme Court underscored that the required procedural safeguards for charging indirect contempt had been observed, including the filing of a written charge and offering petitioners an opportunity to be heard.
The long-standing nature of the dispute (pending for 25 years) further emphasized the court’s impatience with attempts to delay resolution.

Whether petitioners’ failure to implement the directives (reinstatement of shares, issuance of stock certificates, and acknowledgment of the special administratrix’s rights) amounts to indirect contempt.
Whether the actions and motions filed by petitioners legitimately question or obstruct a clear and final court order.

Whether the charge for indirect contempt was correctly filed before the court that originally issued the order.
Whether petitioners’ claims of forum-shopping have any merit given the proper judicial venue for such charges.

Whether the events alleged by petitioners (revocation of the special administratrix’s appointment, procedural issues in implementation, and share pricing discrepancies) qualify as “supervening events” capable of suspending the execution of the final decision.
Whether these alleged events were indeed newly emerged circumstances or pre-existing facts that were already considered by the court.

Whether the directives of the trial and Supreme Courts were sufficiently unambiguous, thereby justifying strict enforcement measures.
Whether petitioners had any legitimate ground to delay execution or re-litigate settled issues.