Doctrine of Non-Interference

Under the doctrine of non-interference, "a trial court has no authority to interfere with the proceedings of a court of equal jurisdiction, much less to annul the final judgment of a co-equal court." In Paper Industries Corporation of the Philippines v. Intermediate Appellate Court, we declared that a court has no jurisdiction to restrain the execution proceedings in another court with concurrent jurisdiction. (G.R. No. 150986; March 2, 2007) We have time and again reiterated the doctrine that no court has the power to interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having the power to grant the relief sought by injunction. This doctrine of non-interference is premised on the principle that a judgment of a court of competent jurisdiction may not be opened, modified or vacated by any court of concurrent jurisdiction. As correctly ratiocinated by the CA, cases wherein an execution order has been issued, are still pending, so that all the proceedings on the execution are still proceedings in the suit. Since the Bacolod RTC had already acquired jurisdiction over the collection suit (Civil Case No. 98-10404) and rendered judgment in relation thereto, it retained jurisdiction to the exclusion of all other coordinate courts over its judgment, including all incidents relative to the control and conduct of its ministerial officers, namely public respondent sheriffs. Thus, the issuance by the Pasig RTC of the writ of preliminary injunction in Civil Case No. 68125 was a clear act of interference with the judgment of Bacolod RTC in Civil Case No. 98-10404.

The jurisprudential "exception" adverted to by petitioner, i.e. Santos v. Bayhon, 199 SCRA 525 (1991), finds no application in this case. In Santos, we allowed the implementation of a writ of execution issued by the Labor Arbiter to be enjoined by order of the RTC where a third party claimant had filed his action to recover property involved in the execution sale, since the Labor Arbiter had no jurisdiction to decide matters of ownership of property and the civil courts are the proper venue therefor. In the case at bar, the Bacolod RTC had jurisdiction and competence to resolve the question of ownership of the property involved had petitioner filed his claim with the said court. (G.R. No. 154623; March 13, 2009)


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