Case Summary (G.R. No. 194767)
Proceedings in RTC Branch 16
Upon return of the original writ unsatisfied, Barroso moved to execute on the counterbond. RTC-Br. 16 conducted a summary hearing, found grounds to include Travellers, and issued an alias writ of execution on April 28, 2009. The sheriff served Travellers with a demand letter.
Issuance of Alias Writ and Demand on Counterbond
Travellers requested time to validate the bond and negotiate. Instead, it filed a petition in RTC-Br. 14 seeking nullification of the bond and prohibition and injunction against enforcement of the alias writ, also claiming damages and attorney’s fees.
Petition for Injunction and RTC Branch 14 Orders
RTC-Br. 14 granted Travellers’ application for a preliminary injunction on July 29, 2009, holding that it was the proper forum to determine the bond’s authenticity and that an injunction was necessary to prevent mootness. The judge rejected the doctrine of non-interference, invoking an exception. The injunction order was affirmed on September 15, 2010.
Petition for Certiorari: Issues Raised
Barroso filed a Rule 65 petition before the Supreme Court, alleging:
- Lack of jurisdiction by RTC-Br. 14 over Travellers’ special civil action.
- Issuance of a preliminary injunction without requiring an injunction bond.
- Interference with the execution order of a co-equal court, in excess of jurisdiction.
Supreme Court Analysis: Hierarchy of Courts
The Court reiterated the doctrine that coordinate trial courts may not enjoin each other’s judgments or processes. The policy on hierarchy of courts preserves orderly administration and confines extraordinary writs to appropriate levels, unless compelling reasons justify an exception.
Supreme Court Analysis: Exception of Patent Nullity
Recognizing that injunctions against the execution of a writ issued by a coordinate court are patent nullities, the Court applied the exception permitting direct relief when an order is void on its face. Analogous jurispru
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Antecedent Facts
- In 2007, petitioner Edgar T. Barroso filed a complaint in RTC-Br. 16, Davao City, for sum of money, damages, and attorney’s fees against Dennis Li, including an application for a writ of attachment.
- RTC-Br. 16 granted the writ of attachment and approved Barroso’s attachment bond.
- Dennis Li posted a counter-attachment bond purportedly issued by Travellers Insurance & Surety Corporation.
- On January 22, 2008, RTC-Br. 16 promulgated a Judgment on Compromise Agreement; Li failed to perform his obligations thereunder.
- Barroso moved for execution; the writ against Li was returned unsatisfied, prompting Barroso’s motion to execute upon the counterbond.
Proceedings in RTC-Br. 16
- By Order dated April 2, 2009, RTC-Br. 16 conducted a summary hearing on liability under the counterbond and recognized Travellers’ obligation thereon.
- An alias writ of execution dated April 28, 2009 was issued against both Dennis Li and Travellers; Sheriff Anggot served a demand letter on Travellers.
- Travellers requested time to validate the bond but instead filed a separate special civil action in RTC-Br. 14 on July 10, 2009.
Petition in RTC-Br. 14
- Travellers’ petition for declaration of nullity, prohibition, injunction, and damages sought:
- A temporary restraining order (TRO) and preliminary injunction enjoining enforcement of the April 28 writ of execution.
- A declaration t