Thursday, August 22, 2019

Judgments of Supreme Court Not Reviewable


The sound, salutary and self-evident principle prevailing in this as in most jurisdictions, is that judgments of the highest tribunal of the land may not be reviewed by any other agency, branch, department, or official of Government. Once the Supreme Court has spoken, there the matter must rest. Its decision should not and cannot be appealed to or reviewed by any other entity, much less reversed or modified on the ground that it is tainted by error in its findings of fact or conclusions of law, flawed in its logic or language, or otherwise erroneous in some other respect. 49 This, on the indisputable and unshakable foundation of public policy, and constitutional and traditional principle.
In an extended Resolution promulgated on March 12, 1987 in In Re: Wenceslao Laureta — involving an attempt by a lawyer to prosecute before the Tanod bayan "members of the First Division of this Court collectively with having knowingly and deliberately rendered an 'unjust extended minute Resolution' with deliberate bad faith in violation of Article 204 of the Revised penal Code ". . . and for deliberatly causing "undue injury" to respondent . . . and her co-heirs because of the "unjust Resolution" promulgated, in violation of the Anti-Graft and Corrupt Practices Act . . . — the following pronouncements were made in reaffirmation of established doctrine: 50

. . . As aptly declared in the Chief Justice's Statement of December 24, 1986, which the Court hereby adopts in toto, "(I)t is elementary that the Supreme Court is supreme — the third great department of government entrusted exclusively with the judicial power to adjudicate with finality all justiciable disputes, public and private. No other department or agency may pass upon its judgments or declare them "unjust." It is elementary that "(A)s has ever been stressed since the early case of Arnedo vs.Llorente (18 Phil. 257, 263 [1911]) "controlling and irresistible reasons of public policy and of sound practice in the courts demand that at the risk of occasional error, judgments of courts determining controversies submitted to them should become final at some definite time fixed by law, or by a rule of practice recognized by law, so as to be thereafter beyond the control even of the court which rendered them for the purpose of correcting errors of fact or of law, into which, in the opinion of the court it may have fallen. The very purpose for which the courts are organized is to put an end to controversy, to decide the questions submitted to the litigants, and to determine the respective rights of the parties. (Luzon Brokerage Co., Inc. vs. Maritime Bldg., Co., Inc., 86 SCRA 305, 316-317)
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Indeed, resolutions of the Supreme Court as a collegiate court, whether an en banc or division, speak for themselves and are entitled to full faith and credence and are beyond investigation or inquiry under the same principle of conclusiveness of enrolled bills of the legislature. (U.S. vs. Pons, 34 Phil. 729; Gardiner, et al. vs. Paredes, et al., 61 Phil. 118; Mabanag vs. Lopez Vito, 78 Phil. 1) The Supreme Court's pronouncement of the doctrine that "(I)t is well settled that the enrolled bill . . . is conclusive upon the courts as regards the tenor of the measure passed by Congress and approved by the President. If there has been any mistake in the printing of the bill before it was certified by the officers of Congress and approved by the Executive [as claimed by petitioner-importer who unsuccessfully sought refund of margin fees] — on which we cannot speculate, without jeopardizing the principle of separation of powers and undermining one of the cornerstones of our democractic system — the remedy is by amendment or curative legislation, not by judicial decree" is fully and reciprocally applicable to Supreme Court orders, resolutions and decisions, mutatis mutandis. (Casco Phil. Chemical Co., Inc. vs. Gimenez, 7 SCRA 347, 350. (Citing Primicias vs. Paredes, 61 Phil. 118, 120; Mabanag vs. Lopez Vito, 78 Phil. 1; Macias vs. Comelec, 3 SCRA 1).
The Court has consistently stressed that the "doctrine of separation of powers calls for the executive, legislative and judicial departments being left alone to discharge their duties as they see fit" (Tan vs. Macapagal, 43 SCRA 677). It has thus maintained in the same way that the judiciary has a right to expect that neither the President nor Congress would cast doubt on the mainspring of its orders or decisions, it should refrain from speculating as to alleged hidden forces at work that could have impelled either coordinate branch into acting the way it did. The concept of separation of powers presupposes mutual respect by and between the three departments of the government. (Tecson vs. Salas, 34 SCRA 275, 286-287).

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THIRD DIVISION [ G.R. No. 235658, June 22, 2020 ] PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RAUL DEL ROSARIO Y NIEBRES, ACCUSED-APPELLANT.

  THIRD DIVISION [ G.R. No. 235658, June 22,  2020  ] PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RAUL DEL ROSARIO Y NIEBRES, ACCUSED...