DEVELOPMENT BANK OF THE PHILIPPINES, REPRESENTED BY ITS GENERAL SANTOS CITY BRANCH HEAD, MARIELA LUZ T. CORTEZ, PETITIONER, VS. MANUEL TE, RESPONDENT.
- G.R. Number: G.R. No. 260664
- Promulgated: 2025-08-18
Doctrine
## Facts of the Case Development Bank of the Philippines (DBP) filed a petition for indirect contempt against Manuel Te (Te) after he failed to surrender 131 certificates of title and 34 other proofs of ownership to the Regional Trial Court (RTC) as ordered. Te, acting as attorney-in-fact for the Abedin group, had previously obtained these documents through a writ of replevin in a civil case against DBP, then moved to dismiss the case due to the Abedin group's lack of interest. The RTC denied the dismissal and directed Te to return the documents, a directive he purportedly ignored. The RTC subsequently found Te guilty of indirect contempt, imposing a fine and imprisonment until compliance. This ruling was affirmed by the Court of Appeals (CA) and became final and executory after the Supreme Court denied Te's petition for review and subsequent motion for reconsideration. Years later, Te filed a Manifestation of Compliance with the RTC, claiming partial compliance by recovering 12 of the titles and arguing that the original order was directed at the Abedin group, not him. The RTC then issued an Order lifting the contempt order, finding that Te's failure to return all titles was not willful due to circumstances beyond his control. DBP moved for reconsideration, which was denied. DBP then filed a petition for certiorari with the CA, arguing that the RTC committed grave abuse of discretion by modifying a final and executory judgment. The CA dismissed DBP's petition, affirming the RTC's decision, stating that the RTC merely gave effect to Te's compliance and did not modify a final judgment. The CA also found no clear showing of how many titles were involved and that Te could not be faulted for not complying fully if he lacked custody. DBP sought reconsideration from the CA, which was denied, leading DBP to file this Petition for Review on Certiorari before the Supreme Court. ## Issues 1. Whether the CA committed grave abuse of discretion by affirming the RTC's ruling which lifted the judgment of indirect contempt against Te. ## Decision / Rationale **Issue 1:** The Supreme Court **reversed and set aside** the Decision and Resolution of the CA, finding that the CA committed grave abuse of discretion. The Court clarified that the contempt proceedings against Te were **civil in nature**, aimed at compelling his compliance with a court order. The RTC's decision finding Te guilty of indirect contempt, affirmed by the CA and subsequently upheld by the Supreme Court, became **final and executory**. The Court reiterated the **doctrine of finality or immutability of judgments**, which holds that a final decision cannot be altered or modified in any respect, even to correct erroneous conclusions. The Supreme Court cited **Industrial Management International Development Corp v. NLRC** and **Eusebio v. Civil Service Commission** to emphasize that once a judgment becomes final, the court loses jurisdiction to amend it. The Court found that the RTC gravely erred in lifting the contempt order, as this effectively nullified a final and executory judgment. While the RTC framed its action as recognizing compliance, its practical effect was to impermissibly modify a final decision, an act beyond its jurisdiction. Consequently, the proceedings conducted by the RTC to amend the final decision were **void ab initio for lack of jurisdiction**. By affirming this unauthorized modification of a final and executory judgment, the CA also committed **grave abuse of discretion**. Grave abuse of discretion arises when a court acts capriciously, whimsically, arbitrarily, or despotically, amounting to an evasion of duty or refusal to perform a legal obligation. The CA's action ran afoul of the **doctrine of immutability of judgments**. Therefore, the Supreme Court held that the CA gravely abused its discretion by affirming the RTC's order that unlawfully disturbed a final and executory judgment. ## Doctrines * **Contempt of Court:** Defined as a willful disregard…
Keywords
Rule 45 Rules of Court, Rule 71 Section 3(b) and (d) and Section 7 1997 Rules of Civil Procedure, Rule 65 Rules of Court, Doctrine of Immutability of Judgments, Finality of Judgments, Indirect Contempt, Civil Contempt, Certiorari, Res Judicata, Willful Disregard, Final and Executory Judgment, Grave Abuse of Discretion, Sui Generis, Criminal Contempt, Petition for Review on Certiorari granted, CA Decision reversed and set aside, RTC Order reversed and set aside, Strict compliance ordered, contempt, civil