REMEDIAL LAW | Lapu-Lapu vs. GMC G.R. No. 141407, September 9, 2002
Lapu-Lapu vs. GMC
G.R. No. 141407, September 9, 2002
FACTS LLDHC (Lapu-Lapu Development and Housing Corporation) defaulted on a loan from GSIS (Government Service Insurance System) secured by a mortgage on the land. GSIS foreclosed on the mortgage and acquired the land through a public auction. LLDHC filed a case in the Manila RTC (Regional Trial Court) to annul the foreclosure. GSIS sold the land to GMC (Group Management Corporation) through a conditional sale agreement. GMC filed a case in the Lapu-Lapu City RTC for specific performance against GSIS, demanding a final deed of sale for the land. The Manila RTC ruled in favor of LLDHC, ordering the reversal of the foreclosure and the return of the land to LLDHC. The Lapu-Lapu City RTC then ruled in favor of GMC, ordering GSIS to execute a final deed of sale for the land to GMC.
Whether the final and fully implemented decision of the Manila RTC could be declared and rendered ineffectual and nugatory by the judgment of the Lapu-Lapu City RTC.
RULING No. Jurisprudence mandates that when a decision becomes final and executory, it becomes valid and binding upon the parties and their successors in interest. 8 Such decision or order can no longer be disturbed or reopened no matter how erroneous it may have been. The Lapu-Lapu City RTC decision became final and executory because LLDHC failed to properly appeal it. The Supreme Court recognized the finality of the Lapu-Lapu City RTC decision by dismissing LLDHC's petition to annul it. Therefore, the Manila RTC decision, despite being implemented, cannot override the final and binding decision of the Lapu-Lapu City RTC. Further, Having the same power and prerogatives, courts of coequal and coordinate jurisdiction cannot interfere with each other’s orders and judgments. The ultimate test to determine the existence of forum shopping is the vexation caused the courts and the litigants by the repeated invocation of substantially the same facts, issues and reliefs, thereby unnecessarily clogging court dockets and creating the possibility of conflicting rulings and decisions.