DOCTRINE OF NON-INTERFERENCE AND JUDICIAL STABILITY

 A court cannot interfere with the decision and actions of another court of co-equal rank. This is to maintain judicial stability. Decisions of courts can be reviewed, revised, modified or affirmed only by courts of higher rank.

Several cases illustrate this:

1. Atty. Tomas Ong Cabili vs. Judge Rasad G. Balindong, AM No. RTJ-10-2225 (September 6, 2011)
2. Hon. Judge Adriano R. Villamor vs. Judge Bernardo LL Salas and George Carlos, GR 101014 (November 13, 1991)
3. Rafael Aquino Sr. vs. Judge Julito B. Valenciano, AM No. MTJ093-746 (December 27, 1994)
4. Russel Esteva Coronado vs. Judge Eddie R. Rojas, AM No. RTC-07-2047 (July 3, 2007)
   
5. Heirs of Simeon Piedad vs. Executive Judge Cesar O. Estrera, AM No. RTJ-09-2170 (December 16, 2009)

Here are excerpts from the case of Cabili vs. Balindong:

A civil action for damages was filed before the RTC in Branch 6 of the Iligan City RTC against Mindanao State University (MSU). The action arose from a vehicular accident that caused the death of Jesus Ledesma and physical injuries to several others.

RTC Iligan City issued a writ of execution. When MSU failed to comply, the sheriff served a notice of garnishment on MSU's bank.

MSU sought to stop the execution by filing a petition with RTC Marawi City for prohibition and mandamus with an application for the issuance of a temporary restraining order and/or preliminary injunction against its bank and the sheriff. The case was raffled to Branch 8 of RTC Marawi presided over by the respondent judge.

The judge issued a TRO against the sheriff and the bank.  The sheriff moved to dismiss the case for lack of jurisdiction, which was granted by RTC Marawi.

Atty. Cabili, counsel for plaintiffs in the civil case for damages, filed an administrative complaint against the judge of RTC Marawi Branch 8. The charge was for gross ignorance of the law, grave abuse of authority, abuse of discretion, and/or grave misconduct prejudicial to the interest of the judicial service. The basis of this administrative case was the judge's act of interfering with the order of a co-equal court, Branch 6 of RTC Iligan City, by issuing a TRO to enjoin the sheriff from garnishing the amount with MSU's bank.

The Office of the Court Administrator found the judge of RTC Marawi "guilty of gross ignorance of the law for violating the elementary rule of non-interference with the proceedings of a court of co-equal jurisdiction."

The Supreme Court's ruling:

The Court finds the OCA's recommendation well-taken.

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. 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.

Thus, we have repeatedly held that 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.[25] 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.