1. General Concepts

Doctrine of Immutability of Judgment and Nunc Pro Tunc Orders

Under the doctrine of immutability of judgment, a decision that has acquired finality becomes immutable and unalterable¹. As expounded in Far East Bank and Trust Company v. Philippine Deposit Insurance Corporation, G.R. No. 172983, 9 June 2026, such an unalterable decision may no longer be modified in any respect, even if the proposed modification is intended to correct erroneous conclusions of fact and law¹.

With respect to modifying or clarifying judgment records, the entry of a nunc pro tunc order requires that the record present visible data of the matter sought to be supplied¹. According to Far East Bank and Trust Company, this exception applies only when the omitted part constitutes a necessary, inevitable, and ordinary consequence of what appears on record¹.