ECHEGARAY VS SECRETARY OF JUSTICE

Facts: On January 4, 1999, the SC issued a TRO staying the execution of petitioner Leo
Echegaray scheduled on that same day. The public respondent Justice Secretary assailed
the issuance of the TRO arguing that the action of the SC not only violated the rule on
finality of judgment but also encroached on the power of the executive to grant reprieve.

Issue: Whether or not the SC, after the decision in the case becomes final and executory,
still has jurisdiction over the case

Held: The finality of judgment does not mean that the SC has lost all its powers or the case.
By the finality of the judgment, what the SC loses is its jurisdiction to amend, modify or
alter the same. Even after the judgment has become final, the SC retains its jurisdiction to
execute and enforce it.

The power to control the execution of the SC’s decision is an essential aspect of its
jurisdiction. It cannot be the subject of substantial subtraction for the Constitution vests the
entirety of judicial power in one SC and in such lower courts as may be established by law.
The important part of a litigation, whether civil or criminal, is the process of execution of
decisions where supervening events may change the circumstance of the parties and
compel courts to intervene and adjust the rights of the litigants to prevent unfairness. It is
because of these unforeseen, supervening contingencies that courts have been conceded
the inherent and necessary power of control of its processes and orders to make them
comform to law and justice.

The Court also rejected public respondent’s contention that by granting the TRO, the Court
has in effect granted reprieve which is an executive function under Sec. 19, Art. VII of the
Constitution. In truth, an accused who has been convicted by final judgment still possesses
collateral rights and these rights can be claimed in the appropriate courts. For instance, a
death convict who becomes insane after his final conviction cannot be executed while in a
state of insanity. The suspension of such a death sentence is indisputably an exercise of
judicial power. It is not a usurpation of the presidential power of reprieve though its effects
are the same as the temporary suspension of the execution of the death convict. In the
same vein, it cannot be denied that Congress can at any time amend the Death Penalty Law
by reducing the penalty of death to life imprisonment. The effect of such an amendment is
like that of commutation of sentence. But the exercise of Congress of its plenary power to
amend laws cannot be considered as a violation of the power of the President to commute
final sentences of conviction. The powers of the Executive, the Legislative and the Judiciary
to save the life of a death convict do not exclude each other for the simple reason that there
is no higher right than the right to life. To contend that only the Executive can protect the
right to life of an accused after his final conviction is to violate the principle of co-equal and
coordinate powers of the 3 branches of the government.