Title
Ngo Bun Tiong vs. Sayo
Case
G.R. No. L-45825
Decision Date
Jun 30, 1988
The Supreme Court annuls an order by a lower court, emphasizing the importance of finality of judgments and criticizing the private respondent for filing multiple cases on the same issue, ultimately ruling in favor of the petitioner and concluding that the execution sale had already been fully satisfied.
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Case Digest (G.R. No. L-45825)

Facts:

  • The case "Ngo Bun Tiong v. Sayo" involves a petition for Certiorari and Prohibition with a prayer for Preliminary Injunction and/or Restraining Order.
  • Petitioner: Ngo Bun Tiong.
  • Respondents: Hon. Marcelino M. Sayo, Presiding Judge of Branch XXXIII, Court of First Instance (CFI) of Rizal, and Galauran & Pilares Construction Co.
  • Petitioner sought annulment of the CFI's order dated February 25, 1977, and subsequent orders in Civil Case No. C-6131.
  • The orders restrained the defendants from removing property from the plaintiff's compound and ordered the return of equipment removed due to an execution sale.
  • Origin: Decision by the CFI of Manila, Branch XIII, in Civil Case No. 96351, where Caltex (Phil.) Inc. was awarded P67,052.32 plus interest, attorney's fees, and costs against Pilares Construction Co.
  • The decision became final and executory, leading to the issuance of a Writ of Execution and an Alias Writ of Execution.
  • Despite multiple motions and petitions by the private respondent, including a dismissed petition for certiorari and mandamus in the Court of Appeals, the execution sale proceeded.
  • Ngo Bun Tiong emerged as the highest bidder at the execution sale.
  • Galauran & Pilares Construction filed a complaint in the CFI of Rizal to nullify the auction sale, leading to the contested orders.
  • Petitioner contended that the CFI of Rizal lacked jurisdiction to annul the execution sale conducted by another CFI branch.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court ruled that the Court of First Instance of Rizal, Branch XXXIII, did not have jurisdiction to annul or set aside the execution sale conducted by the Court of First Instance of Manila, Branch XIII.
  2. The Supreme Court concluded that ...(Unlock)

Ratio:

  • The Supreme Court emphasized the principle of judicial stability, which prohibits courts of concurrent jurisdiction from interfering with each other's judgments.
  • The Court cited established jurisprudence that only the court that rendered the judgment has the authority to modify or vacate it.
  • The decision in Civil Case No. 96351 had...continue reading

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