Lawyerly

GR No. 163598

2015-08-12

AGRARIAN REFORM BENEFICIARIES ASSOCIATION v. FIL-ESTATE INC.

JARDELEZA, J.

We are also prepared to vacate our ruling in G.R. No. 155118. In Heirs of Maura So v. Obliosca, et al.,[65] we departed from our minute resolution issued previously in a different petition because it effectively rendered final and executory an erroneous order of a trial court. We explained then: In Collantes v. Court of Appeals,[66] the Court offered three options to solve a case of conflicting decisions: the first is tor the parties to assert their claims anew, the second is to determine which judgment came first, and the third is to determine which of the judgments had been rendered by a court of last resort. In that case, the Court applied the first option and resolved the conflicting issues anew.

GR No. 194751

2014-11-26

AURORA N. DE PEDRO v. ROMASAN DEVELOPMENT CORPORATION

LEONEN, J.

A petition for annulment of judgment is a recourse that is equitable in character.[111] It is independent of the case[112] and is "allowed only in exceptional cases as where there is no available or other adequate remedy."[113]

GR No. 194751

2014-11-26

AURORA N. DE PEDRO v. ROMASAN DEVELOPMENT CORPORATION

LEONEN, J.

A petition for annulment of judgment is a recourse that is equitable in character.[111] It is independent of the case[112] and is "allowed only in exceptional cases as where there is no available or other adequate remedy."[113]

GR No. 194751

2014-11-26

AURORA N. DE PEDRO v. ROMASAN DEVELOPMENT CORPORATION

LEONEN, J.

However, this court had an occasion to say that an action for annulment of judgment "may not be invoked (1) where the party has availed himself of the remedy of new trial, appeal, petition for relief, or other appropriate remedy and lost; or (2) where he has failed to avail himself of those remedies through his own fault or negligence."[115] Thus, an action for annulment of judgment is not always readily available even if there are causes for annulling a judgment.

GR No. 197486

2014-09-10

RENATO L. DELFINO v. AVELINO K. ANASAO

VILLARAMA, JR., J.

A decision 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.[33] This doctrine of finality and immutability of judgments is grounded on fundamental considerations of public policy and sound practice to the effect that, at the risk of occasional error, the judgments of the courts must become final at some definite date set by law.[34]

GR No. 179643

2013-06-03

ERNESTO L. NATIVIDAD v. FERNANDO MARIANO

BRION, J.

We cannot blame Ernesto for insisting that the PARAD decision can no longer be altered. The doctrine of immutability of final judgments, grounded on the fundamental principle of public policy and sound practice, is well settled. Indeed, once a decision has attained finality, it becomes immutable and unalterable and may no longer be modified in any respect,[41] whether the modification is to be made by the court that rendered it or by the highest court of the land.[42] The doctrine holds true even if the modification is meant to correct erroneous conclusions of fact and law.[43] The judgment of courts and the award of quasi-judicial agencies must, on some definite date fixed by law, become final even at the risk of occasional errors.[44] The only accepted exceptions to this general rule are the correction of clerical errors, the so-called nunc pro tunc entries which cause no prejudice to any party, void judgments, and whenever circumstances transpire after the finality of the decision which render its execution unjust and inequitable.[45]

GR No. 171182

2012-08-23

UNIVERSITY OF PHILIPPINES v. AGUSTIN S. DIZON

BERSAMIN, J.

But the doctrine of immutability of a final judgment has not been absolute, and has admitted several exceptions, among them: (a) the correction of clerical errors; (b) the so-called nunc pro tunc entries that cause no prejudice to any party; (c) void judgments; and (d) whenever circumstances transpire after the finality of the decision that render its execution unjust and inequitable.[90] Moreover, in Heirs of Maura So v. Obliosca,[91] we stated that despite the absence of the preceding circumstances, the Court is not precluded from brushing aside procedural norms if only to serve the higher interests of justice and equity. Also, in Gumaru v. Quirino State College,[92] the Court nullified the proceedings and the writ of execution issued by the RTC for the reason that respondent state college had not been represented in the litigation by the Office of the Solicitor General.

GR No. 181956

2010-11-11

VICTORIA L. TEH v. NATIVIDAD TEH TAN

NACHURA, J.

A decision 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.[35]

GR No. 181956

2010-11-11

VICTORIA L. TEH v. NATIVIDAD TEH TAN

NACHURA, J.

The only exceptions to the general rule are the correction of clerical errors, the so-called nunc pro tunc entries which cause no prejudice to any party, void judgments, and cases where circumstances transpire after the finality of the decision that render its execution unjust and inequitable.[39] Not one of these exceptions is present in this case.

GR No. 161062

2009-07-31

REPUBLIC v. FERVENTINO U. TANGO

QUISUMBING, J.

By express provision of law, the judgment of the court in a summary proceeding shall be immediately final and executory. As a matter of course, it follows that no appeal can be had of the trial court's judgment in a summary proceeding for the declaration of presumptive death of an absent spouse under Article 41 of the Family Code. It goes without saying, however, that an aggrieved party may file a petition for certiorari to question abuse of discretion amounting to lack of jurisdiction. Such petition should be filed in the Court of Appeals in accordance with the Doctrine of Hierarchy of Courts. To be sure, even if the Court's original jurisdiction to issue a writ of certiorari is concurrent with the RTCs and the Court of Appeals in certain cases, such concurrence does not sanction an unrestricted freedom of choice of court forum.[13] From the decision of the Court of Appeals, the losing party may then file a petition for review on certiorari under Rule 45 of the Rules of Court with the Supreme Court. This is because the errors which the court may commit in the exercise of jurisdiction are merely errors of judgment which are the proper subject of an appeal.[14]

GR No. 163794

2008-11-28

REPUBLIC v. NORMELITO J. BALLOCANAG

NACHURA, J.

In the exercise of our mandate as a court of justice and equity,[34] we rule in favor of Reyes pro hac vice. We reiterate that this Court is not precluded from rectifying errors of judgment if blind and stubborn adherence to the doctrine of immutability of final judgments would involve the sacrifice of justice for technicality.[35] Indubitably, to order the reversion of the subject land without payment of just compensation, in absolute disregard of the rights of Reyes over the improvements which he, in good faith, introduced therein, would not only be unjust and inequitable but cruel as well.

GR No. 158642

2008-09-22

ESTATE OF DON FILEMON Y. SOTTO v. MATILDE S. PALICTE

CARPIO, J.

(a) In case of a judgment or a final order against a specific thing, or in respect to the probate of a will, or the administration of the estate of a deceased person, or in respect to the personal, political, or legal condition or status of a particular person or his relationship to another, the judgment or final order is conclusive upon the title to the thing, the will or administration, or the condition, status or relationship of the person; however, the probate of a will or granting of letters of administration shall only be prima facie evidence of the death of the testator or intestate; x x x (Emphasis supplied) Res judicata or bar by prior judgment means that when a right or fact had already been judicially tried on the merits and determined by a court of competent jurisdiction, the final judgment or order shall be conclusive upon the parties and those in privity with them and constitutes an absolute bar to subsequent actions involving the same claim, demand or cause of action.[12] Res judicata promotes the public policy and sound practice that stability should be accorded to final judgments and orders; otherwise, there will be no end to litigation.[13] Thus, even at the risk of occasional errors, judgments of courts should become final at some definite time fixed by law and that parties should not be allowed to litigate the same issues over again.[14]

	GR No. 163598 2015-08-12	AGRARIAN REFORM BENEFICIARIES ASSOCIATION v. FIL-ESTATE INC. JARDELEZA, J.
We are also prepared to vacate our ruling in G.R. No. 155118. In Heirs of Maura So v. Obliosca, et al.,[65] we departed from our minute resolution issued previously in a different petition because it effectively rendered final and executory an erroneous order of a trial court. We explained then: In Collantes v. Court of Appeals,[66] the Court offered three options to solve a case of conflicting decisions: the first is tor the parties to assert their claims anew, the second is to determine which judgment came first, and the third is to determine which of the judgments had been rendered by a court of last resort. In that case, the Court applied the first option and resolved the conflicting issues anew.
	GR No. 194751 2014-11-26	AURORA N. DE PEDRO v. ROMASAN DEVELOPMENT CORPORATION LEONEN, J.
A petition for annulment of judgment is a recourse that is equitable in character.[111] It is independent of the case[112] and is "allowed only in exceptional cases as where there is no available or other adequate remedy."[113]
	GR No. 194751 2014-11-26	AURORA N. DE PEDRO v. ROMASAN DEVELOPMENT CORPORATION LEONEN, J.
A petition for annulment of judgment is a recourse that is equitable in character.[111] It is independent of the case[112] and is "allowed only in exceptional cases as where there is no available or other adequate remedy."[113]
	GR No. 194751 2014-11-26	AURORA N. DE PEDRO v. ROMASAN DEVELOPMENT CORPORATION LEONEN, J.
However, this court had an occasion to say that an action for annulment of judgment "may not be invoked (1) where the party has availed himself of the remedy of new trial, appeal, petition for relief, or other appropriate remedy and lost; or (2) where he has failed to avail himself of those remedies through his own fault or negligence."[115] Thus, an action for annulment of judgment is not always readily available even if there are causes for annulling a judgment.
	GR No. 197486 2014-09-10	RENATO L. DELFINO v. AVELINO K. ANASAO VILLARAMA, JR., J.
A decision 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.[33] This doctrine of finality and immutability of judgments is grounded on fundamental considerations of public policy and sound practice to the effect that, at the risk of occasional error, the judgments of the courts must become final at some definite date set by law.[34]
	GR No. 179643 2013-06-03	ERNESTO L. NATIVIDAD v. FERNANDO MARIANO BRION, J.
We cannot blame Ernesto for insisting that the PARAD decision can no longer be altered. The doctrine of immutability of final judgments, grounded on the fundamental principle of public policy and sound practice, is well settled. Indeed, once a decision has attained finality, it becomes immutable and unalterable and may no longer be modified in any respect,[41] whether the modification is to be made by the court that rendered it or by the highest court of the land.[42] The doctrine holds true even if the modification is meant to correct erroneous conclusions of fact and law.[43] The judgment of courts and the award of quasi-judicial agencies must, on some definite date fixed by law, become final even at the risk of occasional errors.[44] The only accepted exceptions to this general rule are the correction of clerical errors, the so-called nunc pro tunc entries which cause no prejudice to any party, void judgments, and whenever circumstances transpire after the finality of the decision which render its execution unjust and inequitable.[45]
	GR No. 171182 2012-08-23	UNIVERSITY OF PHILIPPINES v. AGUSTIN S. DIZON BERSAMIN, J.
But the doctrine of immutability of a final judgment has not been absolute, and has admitted several exceptions, among them: (a) the correction of clerical errors; (b) the so-called nunc pro tunc entries that cause no prejudice to any party; (c) void judgments; and (d) whenever circumstances transpire after the finality of the decision that render its execution unjust and inequitable.[90] Moreover, in Heirs of Maura So v. Obliosca,[91] we stated that despite the absence of the preceding circumstances, the Court is not precluded from brushing aside procedural norms if only to serve the higher interests of justice and equity. Also, in Gumaru v. Quirino State College,[92] the Court nullified the proceedings and the writ of execution issued by the RTC for the reason that respondent state college had not been represented in the litigation by the Office of the Solicitor General.
	GR No. 181956 2010-11-11	VICTORIA L. TEH v. NATIVIDAD TEH TAN NACHURA, J.
A decision 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.[35]
	GR No. 181956 2010-11-11	VICTORIA L. TEH v. NATIVIDAD TEH TAN NACHURA, J.
The only exceptions to the general rule are the correction of clerical errors, the so-called nunc pro tunc entries which cause no prejudice to any party, void judgments, and cases where circumstances transpire after the finality of the decision that render its execution unjust and inequitable.[39] Not one of these exceptions is present in this case.
	GR No. 161062 2009-07-31	REPUBLIC v. FERVENTINO U. TANGO QUISUMBING, J.
By express provision of law, the judgment of the court in a summary proceeding shall be immediately final and executory. As a matter of course, it follows that no appeal can be had of the trial court's judgment in a summary proceeding for the declaration of presumptive death of an absent spouse under Article 41 of the Family Code. It goes without saying, however, that an aggrieved party may file a petition for certiorari to question abuse of discretion amounting to lack of jurisdiction. Such petition should be filed in the Court of Appeals in accordance with the Doctrine of Hierarchy of Courts. To be sure, even if the Court's original jurisdiction to issue a writ of certiorari is concurrent with the RTCs and the Court of Appeals in certain cases, such concurrence does not sanction an unrestricted freedom of choice of court forum.[13] From the decision of the Court of Appeals, the losing party may then file a petition for review on certiorari under Rule 45 of the Rules of Court with the Supreme Court. This is because the errors which the court may commit in the exercise of jurisdiction are merely errors of judgment which are the proper subject of an appeal.[14]
	GR No. 163794 2008-11-28	REPUBLIC v. NORMELITO J. BALLOCANAG NACHURA, J.
In the exercise of our mandate as a court of justice and equity,[34] we rule in favor of Reyes pro hac vice. We reiterate that this Court is not precluded from rectifying errors of judgment if blind and stubborn adherence to the doctrine of immutability of final judgments would involve the sacrifice of justice for technicality.[35] Indubitably, to order the reversion of the subject land without payment of just compensation, in absolute disregard of the rights of Reyes over the improvements which he, in good faith, introduced therein, would not only be unjust and inequitable but cruel as well.
	GR No. 158642 2008-09-22	ESTATE OF DON FILEMON Y. SOTTO v. MATILDE S. PALICTE CARPIO, J.
(a) In case of a judgment or a final order against a specific thing, or in respect to the probate of a will, or the administration of the estate of a deceased person, or in respect to the personal, political, or legal condition or status of a particular person or his relationship to another, the judgment or final order is conclusive upon the title to the thing, the will or administration, or the condition, status or relationship of the person; however, the probate of a will or granting of letters of administration shall only be prima facie evidence of the death of the testator or intestate; x x x (Emphasis supplied) Res judicata or bar by prior judgment means that when a right or fact had already been judicially tried on the merits and determined by a court of competent jurisdiction, the final judgment or order shall be conclusive upon the parties and those in privity with them and constitutes an absolute bar to subsequent actions involving the same claim, demand or cause of action.[12] Res judicata promotes the public policy and sound practice that stability should be accorded to final judgments and orders; otherwise, there will be no end to litigation.[13] Thus, even at the risk of occasional errors, judgments of courts should become final at some definite time fixed by law and that parties should not be allowed to litigate the same issues over again.[14]

HEIRS OF MAURA SO v. vs.LUCILA JOMOC OBLIOSCA