D. Doctrine of non-interference/judicial stability

1. IN GENERAL

The doctrine of judicial stability or non-interference in the regular orders or judgments of a co-equal court is an elementary principle in the administration of justice: no court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having the power to grant the relief sought by the injunction. (Cabili v. Balindong, En Banc, A.M. No. RTJ-10-225, 06 September 2011)

To ensure the orderly administration of justice, the quintessential doctrine of judicial stability or non-interference between concurrent and coordinate courts is being enforced in our jurisdiction. It provides that the judgment of a court of competent jurisdiction could not be interfered with by any court of concurrent jurisdiction. Acting as an “insurmountable barrier,” it strongly proscribes the exercise of jurisdiction of a court of competent jurisdiction as regards cases relative to that already decided by another co-equal court. (Soliman v. Heirs of Tolentino, G.R. Nos. 229164 & 229186, 02 September 2019)

a. Rationale

The rationale for the rule is founded on the concept of jurisdiction: a court that acquires jurisdiction over the case and renders judgment therein has jurisdiction over its judgment, to the exclusion of all other coordinate courts, for its execution and over all its incidents, and to control, in furtherance of justice, the conduct of ministerial officers acting in connection with this judgment. (Cabili v. Balindong, supra.)

The doctrine of judicial stability or the doctrine of non-interference states that the judgment of a court of competent jurisdiction may not be interfered with by any court of concurrent jurisdiction. The rationale for the same is founded on the concept of jurisdiction – verily, a court that acquires jurisdiction over the case and renders judgment therein has jurisdiction over its judgment, to the exclusion of all other coordinate courts, for its execution and over all its incidents, and to control, in furtherance of justice, the conduct of ministerial officers acting in connection with this judgment. It is an elementary principle in the administration of justice: no court can interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having the power to grant the relief sought by the injunction. (Re: Letter dated March 9, 2020 of DOH Secretary Duque III, En Banc, A.M. No. 20-08-05-SC, 16 February 2021)

b. Splitting jurisdiction

A case where an execution order has been issued is considered as still pending, so that all the proceedings on the execution are still proceedings in the suit. A court which issued a writ of execution has the inherent power, for the advancement of justice, to correct errors of its ministerial officers and to control its own processes. To hold otherwise would be to divide the jurisdiction of the appropriate forum in the resolution of incidents arising in execution proceedings. Splitting of jurisdiction is obnoxious to the orderly administration of justice. (Cabili v. Balindong, supra.)

Rooted on the concept of jurisdiction, a court that acquires jurisdiction over the case and renders judgment therein has jurisdiction over its judgment, to the exclusion of all other coordinate courts, for its execution and over all its incidents, and to control, in furtherance of justice, the conduct of ministerial officers acting in connection with this judgment. (Soliman v. Heirs of Tolentino, supra.)

Alternatively put, the orders and decisions of a competent court cannot be altered, modified or amended by another court of concurrent jurisdiction. (Ibid.)

Adlawan v. Joaquino (20 June 2016)
Since the assailed reconstituted title in this case, from which the petitioner’s title originated was ordered issued by the RTC Branch 14, Cebu City, the respondents’ complaint to annul said title — by reason of the doctrine of non-interference — should have been filed with the CA and not with another RTC branch. Evidently, the RTC Branch 17, Cebu City, as a co-equal court, has no jurisdiction to annul the reconstitution of title previously ordered by the RTC, Branch 14, Cebu City. In fact, the CA was of the same view that the RTC, Branch 17, Cebu City, exceeded its jurisdiction when it declared the order of reconstitution issued by the RTC, Branch 14, Cebu City, as null and void.
Ley v. Union Bank of the Philippines (April 2007)
The Court cannot support the appellate court’s contention that the action for recovery of title is barred by the doctrine of judicial stability or non-interference in the regular orders of judgments of a co-equal court on the premise that the levy on the Tagaytay property in the Makati case was a mere consequence of the judgment for recovery for a sum of money. The judgment did not order the sale of the Tagaytay property in particular as it was not the subject of the litigation therein. It should be made clear, however, that the central issue in the Tagaytay case is whether the spouses Ley are entitled to the physical title, i.e., the Owner’s Copy of the TCT covering the Tagaytay property, and that the pendency of the Tagaytay case does not affect the running of the redemption period for the Tagaytay property.
Pacific Ace Finance Ltd. (PAFIN) v. Eji Yanagisawa (April 2012)
The issue of ownership and liquidation of properties acquired during the cohabitation of Eiji and Evelyn has been submitted for the resolution of the Makati RTC, and is pending41 appeal before the CA. The doctrine of judicial stability or non-interference dictates that the assumption by the Makati RTC over the issue operates as an “insurmountable barrier” to the subsequent assumption by the Parañaque RTC. By insisting on ruling on the same issue, the Parañaque RTC effectively interfered with the Makati RTC’s resolution of the issue and created the possibility of conflicting decisions. Cojuangco v. Villegas states: “The various branches of the [regional trial courts] of a province or city, having as they have the same or equal authority and exercising as they do concurrent and coordinate jurisdiction, should not, cannot and are not permitted to interfere with their respective cases, much less with their orders or judgments. A contrary rule would obviously lead to confusion and seriously hamper the administration of justice.”

Disclaimer: All information herein is for educational and general information only intended for those preparing for the bar exam. These should not be taken as professional legal advice or opinion. Please consult a competent lawyer to address your specific concerns. Any statements or opinions of the author are solely his own and do not reflect that of any organization he may be connected.

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