Title
1st United Constructors Corp. vs. Court of Appeals
Case
G.R. No. 171901
Decision Date
Dec 19, 2006
A sub-contractor claimed a share of a final judgment award, but the Supreme Court ruled that lower courts cannot alter final judgments, annulling orders that modified the award.

Case Summary (G.R. No. 170924)

Factual Background

In the case National Power Corporation v. Alonzo-Legasto, the decision awarded FUCC approximately P74,035,503.50 as just compensation for its services. This decision became final on January 4, 2005. Following this, FUCC initiated proceedings in RTC Branch 99, Quezon City, to have a new sheriff appointed for the enforcement of the judgment. A motion was filed by Bautista, claiming P37,723,823.00 of the awarded amount, alleging ownership of the funds and seeking relief from the trial court.

Trial Court Orders

The trial court found it had jurisdiction to entertain Bautista’s claim, asserting that it could resolve issues relevant to the execution of the judgment. Despite FUCC's objections, the trial court ruled in favor of Bautista, allowing for the distribution of the awarded amounts in a manner that deducted Bautista's claim from FUCC’s entitlement.

Court of Appeals' Response

When FUCC challenged the trial court’s decision, the Court of Appeals denied the prayer for a Temporary Restraining Order (TRO), citing FUCC's failure to demonstrate grounds for the relief sought. It asserted that the orders had attained finality, disputing FUCC's claim that the trial court’s ruling was a nullity and had altered the final judgment in favor of FUCC.

Legal Considerations

The primary issue regarding the Court of Appeals’ refusal to issue the TRO centered on whether it had committed grave abuse of discretion. Furthermore, collateral issues concerning the validity of the trial court's earlier orders were to be evaluated, as they could affect the execution of the original judgment.

Status Quo Order

The Court of Appeals had previously entered a status quo order, which aimed to maintain the situation as it stood prior to the contested trial court ruling. However, this order was ultimately dissolved, which led the appellate court to find FUCC ineligible for a TRO since the trial court's orders were deemed enforceable.

Analysis of Findings

The Supreme Court opined that the appellate court’s denial of the TRO overlooked significant errors made by the trial court in altering the definitive award granted to FUCC. The Court emphasized that the trial court had improperly allowed Bautista’s claim to intervene despite him not being a party to the original case, thereb

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