Case Summary (G.R. No. 167290)
Factual Background
The dispute originates from Civil Case No. C-189, in which Enrique de Leon obtained a judgment of P35,000 against Eusebio Bernabe. Following the issuance of a writ of execution, the city sheriff levied two parcels of land belonging to Bernabe and sold them in an auction to Aurora for P30,194. However, shortly before the end of the redemption period, Bernabe filed a separate action (Civil Case No. C-1217) in Branch XIV, seeking to annul the execution sale, which resulted in a preliminary injunction being issued by Judge Salvador to halt further actions related to the properties sold.
Jurisdictional Conflict
The core issue is the determination of which branch of the Court of First Instance possesses exclusive jurisdiction over the execution sale—whether Branch XII, presided by Judge Cruz, or Branch XIV, presided by Judge Salvador. It is established that the court that issued the original writ of execution retains jurisdiction over all matters related to the enforcement of its judgment, thereby precluding other courts of co-equal jurisdiction from intervening.
Judge Salvador's Actions
Despite Aurora's objections concerning Judge Salvador's jurisdiction, he denied the motion to dismiss Bernabe's case and continued to preside over it. Ultimately, he ordered the sheriff to allow Bernabe to redeem the properties despite the expiration of the statutory redemption period, which prompted Aurora to seek certiorari proceedings against the sheriff and the register of deeds.
Court Rulings on Jurisdiction
The Supreme Court ruled that exclusive jurisdiction to set aside the execution sale was vested in Judge Cruz's court. The Court emphasized the principle that where a court has acquired jurisdiction over a case, no other court of coordinate jurisdiction can interfere with its proceedings or orders. The ruling anchored its decision in prior case law and the doctrine that each court's jurisdiction must be respected to ensure orderly administration of justice.
Resolution of Claims
The Court voided the orders issued by Judge Salvador, including the preliminary injunction and the redemption order that allowed Bernabe to reclaim the properties. The Supreme Court granted the petition for certiorari filed by Aurora, reaffirming that Judge Cruz's court had absolute autho
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Case Overview
- The case involves two separate civil actions, G.R. No. L-30871 and G.R. No. L-31603, which were consolidated due to shared properties and a common jurisdictional conflict between two branches of the Court of First Instance of Rizal in Caloocan City.
- The first case, G.R. No. L-30871, originated from a judgment where Enrique de Leon was awarded P35,000.00 against Eusebio Bernabe. Following the judgment, a writ of execution led to the sale of Bernabe's properties to Aurora P. De Leon.
- The second case, G.R. No. L-31603, was initiated by Bernabe seeking to annul the execution sale and was assigned to a different branch, presided by Judge Serafin Salvador.
Background Facts
- A judgment and subsequent writ of execution were issued in favor of Enrique de Leon in Civil Case No. C-189, resulting in the sale of Bernabe’s properties on February 14, 1967.
- Aurora P. De Leon purchased the properties at auction and registered the sale.
- On February 7, 1968, Bernabe filed a separate civil action against de Leon and others in Judge Salvador's court, questioning the validity of the execution sale.
- Judge Salvador issued a preliminary injunction against the execution sale, which Aurora cont