DOCTRINE OF NON-INTERFERENCE (JUDICIAL STABILITY) IN PHILIPPINE COURTS
(Remedial Law, Legal Ethics & Legal Forms > I. General Principles > G. Nature of Philippine Courts > 4. Doctrine of Non-Interference or Judicial Stability)

1. Overview of the Doctrine

The Doctrine of Non-Interference, sometimes referred to as the Doctrine of Judicial Stability, holds that no court can interfere with the orders, judgments, or decrees of a co-equal court or of courts of concurrent or coordinate jurisdiction. Likewise, a lower court cannot interfere with or reverse the orders or decisions of a higher court. This principle aims to preserve the orderly administration of justice, prevent confusion and conflict of authority, and maintain respect among courts.

This doctrine is deeply embedded in Philippine jurisprudence. Its main thrust is that once a court of competent jurisdiction takes cognizance of a case and renders a valid judgment, that judgment should not be disturbed by another court with the same rank (co-equal or coordinate) or a lower court. The remedy for any perceived error in the decision of a court is through the hierarchy of courts (e.g., appeal, certiorari, or other applicable remedies before a higher court)—not through collateral attacks in another court of the same or lower level.

2. Constitutional and Statutory Foundations

1987 Philippine Constitution
- Article VIII, Section 1: Vests judicial power in one Supreme Court and in such lower courts as may be established by law.
- Article VIII, Section 5: Grants the Supreme Court supervisory and appellate jurisdiction over lower courts. Implicit in this structure is that lower courts do not sit in review of higher courts’ decisions, nor do coordinate courts review each other’s final determinations.
Judiciary Reorganization Laws
- Various statutes, such as Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980), outline the organization and jurisdiction of courts—Supreme Court at the apex, followed by the Court of Appeals (CA), the Sandiganbayan, the Court of Tax Appeals (CTA), Regional Trial Courts (RTCs), and the first-level courts. This statutory framework underlines the hierarchy and the principle that courts must respect each other’s processes and final dispositions.
Rules of Court
- The Revised Rules of Court provide procedural guidelines, including appeals and special civil actions (e.g., Rule 65 on certiorari), affirming that the proper method to challenge a judgment is not to bring the matter to another court of coordinate jurisdiction, but to the appropriate higher court in the judicial hierarchy.

3. Rationale Behind the Doctrine

Orderly Administration of Justice
- Prevents unseemly conflicts and ensures a systematic flow of cases through the appellate structure.
Respect Among Co-Equal Courts
- Each court at a given level has the right to act freely within its jurisdiction; another court of the same rank should not overturn or modify its decisions.
Finality and Stability
- Litigations must come to an end; parties should not be allowed to re-litigate or nullify final judgments in another forum of equal or lower jurisdiction.
- A final and executory decision is considered the “law of the case,” which, in turn, fosters stability in judicial rulings.

4. Key Principles and Illustrative Situations

Co-Equal or Coordinate Courts
- A Regional Trial Court (RTC) in one branch or location generally cannot enjoin or set aside the ruling of another RTC branch of the same rank or in another jurisdiction if the latter has validly acquired jurisdiction over the case.
- The Court of Appeals does not have the power to review the decisions of Sandiganbayan if the latter’s jurisdiction was properly invoked. Both are essentially of the same rank—though functionally specialized, the Sandiganbayan exercises exclusive jurisdiction over certain offenses, and the CA’s general appellate power does not extend over final Sandiganbayan rulings, except via an elevating procedure directly to the Supreme Court.
- The Court of Tax Appeals (CTA) is likewise statutorily endowed with the same rank as the CA concerning tax cases. Hence, the CA cannot casually interfere with the CTA’s final judgments or vice versa.
Lower Courts
- A Municipal/Metropolitan Trial Court (MTC/MeTC) cannot interfere with orders or rulings made by an RTC.
- Similarly, an RTC cannot nullify a final and executory judgment of the CA or the Supreme Court.
Final and Executory Judgments
- Once a judgment becomes final and executory, the issuing court generally loses jurisdiction over it, except to enforce the judgment or correct clerical errors (the “doctrine of immutability of judgments”).
- Another court of concurrent or lower jurisdiction has no authority to alter, restrain, or challenge its execution.
Exclusive or Special Jurisdiction
- In certain cases, specialized courts (e.g., Family Courts, Environmental Courts, or Commercial Courts) exercise exclusive jurisdiction. Another court of equivalent rank cannot usurp or restrain the exercise of that exclusive jurisdiction.

5. Leading Jurisprudence

While not exhaustive, the following Supreme Court decisions illuminate the doctrine:

Mirpuri v. Court of Appeals, G.R. No. 114508 (19 November 1999)
- Emphasized that courts of coordinate jurisdiction cannot interfere with each other’s orders. The resolution of one branch of the RTC cannot be undone by another branch of equal rank.
Riodica v. Court of First Instance of Rizal, G.R. No. L-34973 (21 June 1988)
- The Supreme Court underscored that once jurisdiction is attached and a decision is rendered, the same matter cannot be re-litigated in another coordinate court, preventing multiplicity of suits and inconsistent rulings.
Philippine National Bank v. Castro, G.R. No. L-25978 (28 April 1977)
- Held that a final judgment, once it has attained finality, cannot be interfered with by any court except to correct clerical errors or to enforce the judgment.
Sioson v. Hon. Bugarin
- Reiterated that jurisdiction properly exercised by one court cannot be undermined by a court of the same rank, thus preserving judicial stability.

These rulings, among many others, firmly establish the principle that disputes resolved before one tribunal of competent jurisdiction cannot be subjected to review, modification, or interference by another of equal or lesser rank.

6. Exceptions and Related Concepts

Hierarchy of Courts and Appellate Review
- The doctrine does not bar a properly filed appeal or petitions for certiorari, prohibition, or mandamus before a higher court. It is precisely through these remedies that erroneous rulings of a lower or co-equal court may be reviewed, but only by a higher court in the judicial hierarchy (i.e., the Supreme Court, or in certain instances, the CA reviewing an RTC decision).
Administrative Supervisory Power of the Supreme Court
- The Supreme Court exercises administrative supervision over all courts and court personnel. However, this supervisory power is distinct from the judicial power of review. It generally pertains to matters of discipline, organization, and policy—not the reconsideration of merits decided by co-equal courts in final judgments.
Grave Abuse of Discretion
- In extraordinary circumstances, a petition for certiorari may lie directly with the Supreme Court (or with the Court of Appeals, if it is a lower court’s act in question) if the coordinate or lower court acted with grave abuse of discretion amounting to lack or excess of jurisdiction. This is not so much an “interference” as it is the recognized corrective mechanism provided by the Constitution and the Rules of Court to ensure that courts do not exercise power arbitrarily.
When the Action is Not an Interference
- A new and independent action involving different subject matter, different issues, or different causes of action is not deemed an interference, even if it has a tangential connection to another case. The key is whether the second court is being asked to restrain, reverse, or overturn a validly acquired and exercised jurisdiction of the first court over a specific controversy.

7. Practical Implications

Forum Shopping
- Litigants who attempt to circumvent an unfavorable judgment by filing a new case before another court of equal or lower rank may be engaging in forum shopping, which is strictly prohibited. Courts may dismiss such actions outright and penalize the erring party or counsel.
Respecting Final Judgments
- Lawyers must counsel clients that final and executory judgments cannot be undone through new suits in another co-equal court. The proper remedies lie in appeal or extraordinary writs before the appropriate higher court.
Efficiency in Judicial Process
- By recognizing the doctrine, courts avoid duplication of judicial labor, limit conflicting rulings, and expedite the finality of decisions—ultimately improving the administration of justice.
Strategies in Litigation
- Practitioners must carefully assess jurisdiction and the hierarchy of courts when deciding on the proper remedy—whether a direct appeal, certiorari, or other special civil actions—to ensure compliance with the doctrine and avoid having their pleadings dismissed or ignored.

8. Conclusion

The Doctrine of Non-Interference (Judicial Stability) is a cornerstone of the Philippine judicial system, reinforcing the fundamental hierarchy of courts and ensuring that once a court of competent jurisdiction has rendered a decision, a co-equal or lower court cannot modify, enjoin, or restrain its execution. This principle upholds the finality of judgments, promotes respect among courts, and is integral to an orderly and efficient administration of justice. Lawyers, litigants, and judges alike must be vigilant in observing this doctrine, resorting to the proper channels of appeal or certiorari rather than attempting to undermine a valid judgment through collateral or parallel actions.