G.R. No. 18940 ; April 27, 1922
S. SHIOJI, petitioner, vs. Honorable GEO R. HARVEY, Judge of First Instance of Manila, PACIFIC MAIL STEAMSHIP CO. and TOYO KISEN KAISHA, respondents.

FACTS

In a civil case (No. 19471), the Court of First Instance of Manila rendered judgment in favor of plaintiff S. Shioji against the defendants. The defendants appealed to the Supreme Court (R.G. No. 18592). Under Supreme Court Rule 21, appellants had 30 days from receipt of the printed bill of exceptions to file their brief. They failed to file within this period and their subsequent motion for extension was denied for being filed out of time. Pursuant to Supreme Court Rule 24(a), the appeal was dismissed. The records were remanded to the lower court for execution of the judgment. To prevent execution, the defendants filed a new action in the Court of First Instance (No. 21905), alleging that the Supreme Court’s judgment was unconscionable and rendered without due process, and that Rule 24(a) was unconstitutional. Judge Harvey issued a preliminary injunction enjoining the execution. Shioji then filed this original action for prohibition in the Supreme Court to compel Judge Harvey to desist from interfering with the execution.

ISSUE

1. Whether a Court of First Instance has jurisdiction to interpret, review, or obstruct the enforcement of a final judgment of the Supreme Court.
2. Whether Supreme Court Rule 24(a), providing for the dismissal of an appeal for failure to file the appellant’s brief on time, is unconstitutional, null, and void.

RULING

1. *On the jurisdiction of the lower court: No. A lower court has no jurisdiction to interpret, review, or reverse a judgment of the Supreme Court. Its only function upon receipt of the remanded records is the ministerial duty to issue the order of execution. The lower court is bound by the decree as the law of the case and must carry it into execution according to the mandate. Any interference by an inferior court with a final Supreme Court decision is intolerable and would lead to judicial chaos. The preliminary injunction issued by Judge Harvey is therefore void.

2. On the validity of Rule 24(a):* The rule is valid. Rule 24(a) is not in conflict with any law. It is a necessary rule for orderly procedure and for regulating the conduct of business in the Supreme Court. It relates to a matter of practice and procedure over which the Legislature has not exercised its power, and it does not operate to deprive a party of any statutory right. The Supreme Court has inherent power to promulgate such rules reasonably necessary for the administration of justice within its jurisdiction. An appeal is neither an inherent right nor a necessary element of due process of law.

The writ of prohibition is granted, and the preliminary injunction issued by this Court is made permanent. The respondent Judge is ordered to desist from interfering with the execution of the judgment in the original case.