FACTS: On Aug
1993, thousands of banana plantation workers instituted a class suit in US for
damages against 11 foreign corporations, Chiquita brands being one of those 11
companies. The claimants claimed to have been exposed to dibromochloropropane
(DBCP) while working in the plantation. As a result, these workers suffered serious
and permanent injuries to their reproductive system.
However US courts dismissed the complaint based on forum
non conveniens. On May 1996, the claimants filed a complaint on the same 11
corporations in the RTC of Panabo City, Davao. Before pre-trial the petitioner
and the claimants entered into a compromise agreement with the claimants. The
agreement states that; the petitioner shall be release from all or their
obligation after they deposited an escrow amount in favor of the claimant which
would be administered by a third person/ mediator.
The RTC of Panabo approved the compromised agreement and
dismissed the petition of the claimant.
After dismissal of the civil claim the claimants moved for
the execution of the compromise agreement.
The petitioner opposed the execution on the ground of
mootness; they argued that they had already complied with their obligation by
depositing the settlement amount into an escrow account.
However, RTC of Panabo granted the motion for execution
because there was no proof that they have fulfilled their obligation.
On May 2003 petitioner filed a motion to suspend the
execution and be allowed to present evidence on their behalf.
During the hearing of the case, the claimants picketed
outside the court room and accused the RTC judge of Panabo as a corrupt
official who delayed the execution. Petitioner requested for change of venue
and was granted.
The case was transferred and now under the jurisdiction of
the RTC of Davao city. On July 2009, the RTC of Davao city through Judge Omelio
ordered the execution of the compromised agreement.
Aggrieved by the RTC’s decision, the
petitioner filed for a petition for certiorari even without a prior appeal to
the CA.
Petitioner allege that the respondent Judge committed grave
abuse of discretion in issuing the writ of execution and ordering them to
directly pay each of the claimant contrary to the compromise agreement between
petitioner and claimant.
ISSUES: 1. Whether or not the hierarchy of courts
was violated when the petitioner filed for certiorari without appealing first
to the CA.
2. Whether or not Judge Omelio committed grave abuse of
discretion.
HELD: 1. No.
Under the principle of hierarchy or courts, direct recourse to the SC is
improper because SC is a court of last resort and must remain to be so in order
for it to satisfactorily perform its constitutional functions.
Nonetheless, the invocation of the SC’s original
jurisdiction to issue writs of certiorari has been allowed in certain instances
on the ground of special and important reasons clearly stated in the petition,
such as, 1. When dictated by public welfare and advancement of public policy, 2.
When demanded by broader interest of justice, 3. Where the challenged orders
were patent nullities or 4. When analogous exceptional and compelling
circumstances called for and justified the immediate and direct handling of the
case.
In the case at hand, it was clearly stated that the case is
in need of a broader interest of justice, as it may prejudice any or both
parties when delayed.
2. Yes. Courts can neither amend nor modify the terms and
conditions of a compromise validly entered into by the parties. A writ of
execution that varies the respective obligation of the parties under a
judicially approved compromise settlement is void. Hence Judge Omelio committed
grave abuse of discretion.
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