1. Immutability of Final Judgments; Exceptions

Exceptions:

• When the new law expressly provides for retroactive application;
• When the change of jurisdiction is curative in character. (Vda. de Bal!esteros v. Rural Bank of Canaman. G.R. No. 176250, 2010).

Updated: The Court may relax the immutability of a final judgment to serve substantial justice in matters affecting life, liberty, honor, or property (People v. De Atras, G.R. No. 197252, 23 June 2021).

Doctrine of Immutability of judgments

A judgment that has acquired finality becomes immutable and unalterable, and may no longer be modified in any respect even if the modification is meant to correct erroneous conclusions of fact or law and whether it will be made by the court that rendered it or by the highest court of the land.

The doctrine of immutability and inalterability of a final judgment has a two-fold purpose:

• To avoid delay in the administration of justice and thus, procedurally, to make orderly the discharge of judicial business; and
• To put an end to judicial controversies, at the risk of occasional errors, which is precisely why courts exist.

Updated: A final judgment is generally immutable, but the Court may relax that rule to serve substantial justice in matters affecting life, liberty, honor, or property (People v. De Atras, G.R. No. 197252, 23 June 2021).

Exceptions:

• Correction of clerical errors;
• Nunc pro tunc entries that cause no prejudice to any party;
• Void judgments; and
• Whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable. (Apo Fruits and Hijo Plantation vs. CA, G.R. No. 164195, 2009)

Note: A supervening event, to be sufficient to stay or stop the execution, must alter or modify the situation of the parties under the decision as to render the execution inequitable, impossible, or unfair. The supervening event cannot rest on unproved or uncertain facts. (Abrigo vs. Flores, G.R. No. 160786, 2013)

Doctrine of immutability of a final judgment may be relaxed only to serve the ends of substantial justice in order to consider certain circumstances like:

• Matters of life, liberty, honor or property;
• Existence of special or compelling circumstances;
• Merits of the case;
• Cause not being entirely attributable to the fault or negligence of the party favored by the suspension of the doctrine;
• Lack of any showing that the review sought is merely frivolous and dilatory;
• Other party will not be unjustly prejudiced by the suspension. (Abrigo vs. Flores, G.R. No. 160786, 2013)

When execution of final and executory judgments may be ENJOINED:

• Upon filing of a petition for relief from judgment, the court in which the petition is field may grant preliminary injunction for the preservation of the rights of the parties pending the proceedings;
• In an attack against a judgment which is void for lack of jurisdiction or was obtained through fraud, the court in which the action for certiorari, injunction, or annulment is filed may grant preliminary injunction; and
• On equitable grounds. (Feria and Noche, Civil Procedure Annotated, 2013 ed., vol. 2, p. 130)

General Rule: The dispositive portion of the decision is that part that becomes the subject of execution.

Exceptions:

Where there is ambiguity, the body of the opinion may be referred to for purposes of construing the judgment. (Mutual Security Insurance Corporation v. Court of Appeals, G.R. No. L-47018, 1987)

Where extensive and explicit discussion and settlement of the issue is found in the body of the decision. (Wilson Ong Ching Kian Chung, et al v. Chinese National Cereals Oil and Foodstuffs Import and Export Corp, et al. G.R. No. 131502, June 8, 2000)

NATURE OF THE RIGHT TO APPEAL

DOCTRINE OF FINALITY/IMMUTABILITY OF JUDGMENT; EXCEPTION

Doctrine of Immutability of Judgments (Final Judgment Rule)

A judgment that has acquired finality becomes immutable and unalterable and may no longer be modified in any respect even if the modification is meant to correct erroneous conclusions of fact or law and whether it will be made by the court that rendered it or by the highest court of the land.

The doctrine of immutability and inalterability of a final judgment has a two-fold purpose:

• To avoid delay in the administration of justice and thus, procedurally, to make orderly the discharge of judicial business
• To put an end to judicial controversies, at the risk of occasional errors, which is precisely why courts exist

Updated: The Court may relax the immutability of a final judgment to serve substantial justice in matters affecting life, liberty, honor, or property (People v. De Atras, G.R. No. 197252, 23 June 2021).

Exceptions

• Correction of clerical errors;
• Nunc pro tunc entries that cause no prejudice to any party;
• Void judgments; and
• Whenever circumstances transpire after the finality of the decision rendering its execution unjust and unequitable. (Apo Fruits and Hijo Plantation vs. CA, GR No. 164195, 2009)

Note: A supervening event, to be sufficient to stay or stop the execution, must alter or modify the situation of the parties under the decision as to render the execution inequitable, impossible, or unfair. The supervening event cannot rest on unproved or uncertain facts. (Abrigo vs. Flores, GR No. 160786, 2013)

Doctrine of immutability of a final judgement may be relaxed only to serve the ends of substantial justice in order to consider certain circumstances like:

• Matters of life, liberty, honor, or property;
• Existence of special or compelling circumstances;
• Merits of the case;
• Cause not being entirely attributable to the fault or negligence of the party favored by the suspension of the doctrine
• Lack of any showing that the review sought is merely frivolous and dilatory;
• Lack of any showing that the review sought is merely frivolous and dilatory;

An appeal taken by filing a notice of appeal (and a record on appeal, when proper) from a judgment or final order of the MTC on questions of fact and law.

ENTRY OF JUDGMENT AND FINAL ORDER

If no appeal or motion for new trial or reconsideration is filed within the reglementary period, the judgment or final order shall be entered by the Clerk in the Book of Entries of Judgment. Date of the finality of the judgment or final order shall be deemed to be the DATE OF ITS ENTRY. (Rule 36, Sec. 2)

Judgment is deemed FINAL when it disposes of a case in a manner that leaves NOTHING more to be done by the court in respect thereto. (Rule 36, Sec. 1)

General Rule: After judgment has become final and executory, the court cannot amend the same.

Amendment May Be Possible in the Following Instances:

• To make corrections of clerical errors but not substantial amendments;
• To clarify an ambiguity which is borne out by and justifiable in the context of the decision; and
• In judgments for support, which can always be amended from time to time.

Entry of judgment or final order is important for the reckoning of reglementary periods such as the 5-year period for execution by motion or the 6-month period for a petition for relief (Regalado, Remedial Law Compendium, 9th Ed.)

The judgment or final order has the effect of RES JUDICATA between the two parties.

Updated: The Court may relax the immutability of a final judgment to serve substantial justice in matters affecting life, liberty, honor, or property (People v. De Atras, G.R. No. 197252, 23 June 2021).

Exceptions under Jurisprudence:

• When the factual findings of the Court of Appeals and the trial court are contradictory;
• When the conclusion is a finding grounded entirely on speculation, surmises, or conjectures;
• When the inference made by the Court of Appeals from its findings of fact is manifestly mistaken, absurd, or impossible;
• When there is a grave abuse of discretion in the appreciation of facts;
• When the Appellate Court, in making its findings, went beyond the issues of the case and such findings are contrary to the admissions of both appellant and appellee;
• When the judgment of the Court of Appeals is premised on a misapprehension of facts;
• When the Court of Appeals failed to notice certain relevant facts which, if properly considered, would justify a different conclusion;
• When the findings of fact are themselves conflicting;
• When the findings of fact are conclusions without citation of the specific evidence on which they are based; and
• When the findings of fact of the Court of Appeals are premised on the absence of evidence but such findings are contradicted by the evidence on record. (Local Superior vs. Jody King, G.R. No. 141715, 2005)