## Facts
1. **Initial Decision**: On March 31, 1999, the Court of Appeals (CA) ruled in CA-G.R. SP No. 44261 declaring Mary Jane G. Dy Chiao subsidiarily liable for the amount of P5,711,164.00.
2. **Execution Proceedings**: The decision was affirmed by the Supreme Court and a writ of execution was issued by RTC Branch 19. Sheriff Bolivar reported that the principal obligor, Benedick Arevalo, had no assets and recommended the issuance of an alias writ against Dy Chiao’s properties.
3. **Auction of Properties**: On November 21, 2008, the sheriff auctioned Dy Chiao’s properties, with two parcels sold for P8,000,000.
4. **Further Execution**: Without new alias writ or court order, the sheriff continued to levy additional properties registered under Dy Chiao’s name.
5. **Petition for Prohibition**: On May 13, 2009, Dy Chiao filed for prohibition and a temporary restraining order (TRO) to stop further execution, which was initially granted by RTC.
6. **Jurisdictional Issue**: The case was dismissed by RTC Branch 23 due to lack of jurisdiction, stating that execution proceedings are incidents of the original civil case before RTC Branch 19.
7. **Appeal to CA**: Dy Chiao filed a motion for extension of time to file a petition for review on certiorari to the CA, which was denied on November 12, 2009, on grounds that it should have been filed with the Supreme Court.
## Issues
1. **Jurisdictional Challenge**: Whether it was proper for RTC Branch 23 to deny the original petition for prohibition on jurisdictional grounds.
2. **Procedural Error**: Whether the CA erred in denying the motion for extension on the premise that the appeal should have been brought to the Supreme Court rather than the CA, despite the principle of hierarchy of courts.
## Court’s Decision
1. **Jurisdiction of RTC Branch 19**: The Supreme Court affirmed that RTC Branch 19 retained control over the execution proceedings as incidents of the main case. Therefore, RTC Branch 23 rightly dismissed the prohibition case, respecting the doctrine of judicial stability.
2. **Erroneous Appeal to CA**: The Supreme Court upheld the CA’s decision to deny the motion for extension. The appeal, involving questions of law, should have been filed directly to the Supreme Court per Section 1, Rule 45 of the Rules of Court.
### Analysis:
– **Jurisdiction Respect**: The Supreme Court emphasized that any challenge or clarification regarding the execution processes should have been addressed by RTC Branch 19. Undertaking actions in another court disrupts judicial stability and coordination.
– **Procedural Adherence**: Compliance with procedural rules is imperative. Filing an appeal to the wrong court, when questions of law are involved, leads to dismissal. The CA was correct in its refusal to entertain the motion for extension due to improper forum.
## Doctrine
The case primarily reiterates the **Doctrine of Judicial Stability**, which mandates non-interference by courts of equal jurisdiction in each other’s judgments or decrees. Furthermore, it underlines that the proper forum for appeals involving pure questions of law is the Supreme Court.
## Class Notes
– **Elements of Judicial Stability**:
– No court should interfere with the judgments or rulings of another court of concurrent jurisdiction.
– Any challenge to a proceeding involving the execution of a decision should be filed in the court that issued the original ruling.
– **Relevant Provisions**:
– **Section 1, Rule 45, Rules of Court**: Appeals raising only legal questions must be filed with the Supreme Court.
– **Section 2, Rule 50, Rules of Court**: Improper appeals raising questions of law to the CA must be dismissed.
Simplified Memorization:
– Properly identify the correct forum for appeals.
– Uphold the principle of judicial stability: avoid filing multiple actions across courts of concurrent jurisdiction.
## Historical Background
This case emerged from procedural complexities in the hierarchical structure of the Philippine judiciary, testing the balance between filing appeals correctly and respecting jurisdictional boundaries. It provides a pivotal point on procedural rigors in appeals concerning the Rules of Court and emphasizes the importance of judicial stability in the orderly administration of justice.
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