Lawyerly

GR No. 192947

2015-12-09

MELANIE E. DE OCAMPO v. RPN-9

LEONEN, J.

This rule, however, does admit of exceptions. As this court explained in Sacdalan v. Court of Appeals:[40]

GR No. 192947

2015-12-09

MELANIE E. DE OCAMPO v. RPN-9

LEONEN, J.

None of the four exceptions mentioned in Sacdalan v. Court of Appeals[47] that warrant a modification of judgments that have attained finality is availing in this case.

AM No. 09-5-2-SC

2013-04-11

IN MATTER OF BREWING CONTROVERSIES IN ELECTIONS OF INTEGRATED BAR OF PHILIPPINES. ATTYS. MARCIAL M. MAGSINO v. ATTYS. ROGELIO A. VINLUAN

MENDOZA, J.

1. Eugene Tan (Capiz) Western Visayas January 28, 1990-April 1991[17] 2. Numeriano Tanopo, Jr. (Pangasinan) Central Luzon April 1991-June 30, 1991 3. Mervin Encanto (Quezon City) Greater Manila 1993-1995 4. Raoul R. Angangco (Makati) Southern Luzon 1995-1997 5. Jose Aguila Grapilon (Biliran) Eastern Visayas 1997-1999 6.Arthur Lim (Zambasulta) Western Mindanao 1999-2001 7. Teofilo Pilando, Jr. (Kalinga Apayao) Northern Luzon 2001-2003 8. Jose Anselmo Cadiz (Camarines Sur) Bicolandia 2003-2005

GR No. 155830

2012-08-15

NUMERIANO P. ABOBON v. FELICITAS ABATA ABOBON

BERSAMIN, J.

First of all, a fundamental principle in land registration under the Torrens system is that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein.[12] The certificate of title thus becomes the best proof of ownership of a parcel of land;[13] hence, anyone who deals with property registered under the Torrens system may rely on the title and need not go beyond the title.[14] This reliance on the certificate of title rests on the doctrine of indefeasibility of the land title, which has long been well-settled in this jurisdiction. It is only when the acquisition of the title is attended with fraud or bad faith that the doctrine of indefeasibility finds no application.[15]

GR No. 168105

2011-07-27

LAND BANK OF PHILIPPINES v. SEVERINO LISTANA

VILLARAMA, JR., J.

It is a fundamental legal principle that 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 and law, and whether it be made by the court that rendered it or by the highest court of the land. The only exceptions to the general rule on finality of judgments are 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.[32] Indeed, litigation must end and terminate sometime and somewhere, even at the risk of occasional errors.[33]

GR No. 178984

2009-08-19

ERLINDA MAPAGAY v. PEOPLE

CHICO-NAZARIO, J.

Once a judgment attains finality, it becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by this Court.[34] Decisions that have long become final and executory cannot be annulled by courts, and the appellate court is deprived of jurisdiction to alter the trial court's final judgment.[35] This doctrine is founded on considerations of public policy and sound practice that, at the risk of occasional errors, judgments must become final at some point in time.[36]

GR No. 163208

2008-08-13

HEIRS OF JUAN VALDEZ v. CA

BRION, J.

Even granting that the first May 5, 2003 Resolution became final and executory, the rule on immutability of judgment does not apply in cases where what is to be modified or altered involves: (a) the correction of clerical errors; (b) the so-called nunc pro tunc entries which cause no prejudice to any party; (c) void judgments [such as a dismissal without prejudice that was not intended to be issued] and those where circumstances transpire after the finality that render the execution or enforcement, as in this case, of the judgment unjust or inequitable.[20] To be sure, the rule does not apply in cases where a supervening event - such as the mistake undisputably committed by the court (i.e., the unintended release of one of the resolutions, thus resulting in the conflict and confusion) - took place.[21]

GR No. 147082

2008-01-28

HEIRS OF MAURA SO v. vs.LUCILA JOMOC OBLIOSCA

NACHURA, J.

The doctrine of finality of judgment is grounded on the fundamental principle of public policy and sound practice that, at the risk of occasional error, the judgment of courts and the award of quasi-judicial agencies must become final on some definite date fixed by law.[24] 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 whenever circumstances transpire after the finality of the decision which render its execution unjust and inequitable.[25] Again, none of these exceptions is present in this case.

GR No. 170099

2007-11-28

COLBY CONTSRUCTION v. NLRC

CHICO-NAZARIO, J.

Petitioners' theory of substantial compliance totally transgresses the basic principle that the finality of a decision is a jurisdictional event that cannot be made to depend on the convenience of the party. To allow the party to determine at his discretion when to post an appeal bond, which is a necessary requisite in the perfection of an appeal, would in effect, unduly delay the running of the period for a decision to attain its finality, thereby completely negating the purpose of the rule on the completeness of service, which is to place the date of receipt of pleadings, judgments and processes beyond the power of the party being served to determine at his pleasure.[29]

AM NO. RTJ-04-1840

2007-08-02

LAGCAO v. JUDGE IRENEO LEE GAKO

CORONA, J.

We agree with the OCA that respondent had legal basis in issuing the writ in his March 27, 2000 resolution. It is true that complainants had in their favor a final and executory decision by the MTCC which had become immutable and unalterable.[33] However, one of the exceptions to the principle of immutability of final judgments is the existence of supervening events. Supervening events refer to facts which transpire or new circumstances which develop after the judgment acquires finality, rendering its execution unjust and inequitable.[34]

GR NO. 158992

2007-01-26

REPUBLIC v. SPS. JOSE AND AMELIA LURIZ

VELASCO, JR., J.

In the same manner, the Court in Sacdalan v. Court of Appeals affirmed the reinstatement of an appeal previously dismissed for failure to pay the docket fees. It held that the appeal was dismissed not because the appellant lacked interest in the case, but because of lack of proper notice. Thus, it considered the reinstatement of the appeal as just and proper because the "interest of substantial justice far outweighs whatever negligence"[14] was committed.

GR NO. 135817

2006-11-30

REYNALDO RODRIGUEZ v. CONCORDIA ONG LIM

CALLEJO, SR., J.

Petitioners cannot raise the defense of indefeasibility of a Torrens title with respect to TCT No. T-168607 because "the principle of indefeasibility of a Torrens title does not apply where fraud attended the issuance of the title. The Torrens title does not furnish a shield for fraud."[21] They cannot deny any knowledge of the fraud that attended the transactions involving the subject lots, including their acquisition thereof. Stated differently, petitioners cannot claim that they were purchasers in good faith and for value because the transactions involving the subject lots were so replete with badges of fraud and irregularities that should have put them on guard about the defects in the respective titles of Frisco Gudani and Eduardo Victa.

GR NO. 129165

2006-10-30

SPS. RODRIGO COLOSO AND ELISA COLOSO v. SECRETARY ERNESTO V. GARILAO

VELASCO, JR., J.

In Sacdalan v. Court of Appeals, we ruled that "[a] decision that 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."[24]

GR NO. 145420

2006-09-19

A. RAFAEL C. DINGLASAN JR. v. CA

CHICO-NAZARIO, J.

"Sec. 10. Entry of judgments and final resolutions. - If no appeal or motion for new trial or reconsideration is filed within the time provided in these Rules, the judgment or final resolution shall forthwith be entered by the clerk in the book of entries of judgments. The date when the judgment or final resolution becomes executory shall be deemed as the date of its entry. The record shall contain the dispositive part of the judgment or final resolution and shall be signed by the clerk, with a certificate that such judgment or final resolution has become final and executory. After the judgment or final resolution is entered in the entries of judgment, the case shall be laid to rest. A decision that acquired finality becomes immutable and unalterable and it 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.[24]

GR NO. 159520

2006-09-19

FELISA L. PEÑA v. GOVERNMENT SERVICE INSURANCE SYSTEM

CHICO-NAZARIO, J.

The rule on finality of decisions, orders or resolutions of a judicial, quasi-judicial or administrative body is "not a question of technicality but of substance and merit," the underlying consideration therefore, being the protection of the substantive rights of the winning party.[39] Nothing is more settled in law than that 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.[40]

ADM CASE NO. 5649

2006-01-27

DANDY V. QUIJANO v. GEOBEL A. BARTOLABAC

TINGA, J.

Once the case is decided with finality, the controversy is settled and the matter is laid to rest. The prevailing party is entitled to enjoy the fruits of his victory while the other party is obliged to respect the court's verdict and to comply with it. We reiterate our pronouncement in Salicdan v. Court of Appeals: [29]

GR NO. 127967

2005-12-14

FEDERATED REALTY CORPORATION v. CA

TINGA, J.

Time and again, we have upheld the fundamental principle in land registration that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein.[30] It becomes the best proof of ownership of a parcel of land.[31] One who deals with property registered under the Torrens system may rely on the title and need not go beyond the same.[32] Such principle of indefeasibility has long been well-settled in this jurisdiction and it is only when the acquisition of the title is attended with fraud or bad faith that the doctrine finds no application.[33]

GR NO. 158971

2005-08-25

MARIANO Y. SIY v. NLRC

CORONA, J.

Once a case is decided with finality, the controversy is settled and the matter is laid to rest. The prevailing party is entitled to enjoy the fruits of his victory while the other party is obliged to respect the court's verdict and to comply with it. We reiterate our pronouncement in Sacdalan v. Court of Appeals:[18]

GR NO. 125585

2005-06-08

HEIRS OF EDUARDO MANLAPAT v. CA

TINGA, J.

Time and again, this Court has ruled that the principle of indefeasibility of a Torrens title does not apply where fraud attended the issuance of the title, as was conclusively established in this case. The Torrens title does not furnish a shied for fraud.[47] Registration does not vest title. It is not a mode of acquiring ownership but is merely evidence of such title over a particular property. It does not give the holder any better right than what he actually has, especially if the registration was done in bad faith. The effect is that it is as if no registration was made at all.[48] In fact, this Court has ruled that a decree of registration cut off or extinguished a right acquired by a person when such right refers to a lien or encumbrance on the land not to the right of ownership thereof which was not annotated on the certificate of title issued thereon.[49]

GR NO. 146006

2005-04-22

JOSE C. LEE v. RTC OF QUEZON CITY

CORONA, 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 whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable. [26]

	GR No. 192947 2015-12-09	MELANIE E. DE OCAMPO v. RPN-9 LEONEN, J.
This rule, however, does admit of exceptions. As this court explained in Sacdalan v. Court of Appeals:[40]
	GR No. 192947 2015-12-09	MELANIE E. DE OCAMPO v. RPN-9 LEONEN, J.
None of the four exceptions mentioned in Sacdalan v. Court of Appeals[47] that warrant a modification of judgments that have attained finality is availing in this case.
	AM No. 09-5-2-SC 2013-04-11	IN MATTER OF BREWING CONTROVERSIES IN ELECTIONS OF INTEGRATED BAR OF PHILIPPINES. ATTYS. MARCIAL M. MAGSINO v. ATTYS. ROGELIO A. VINLUAN MENDOZA, J.
1. Eugene Tan (Capiz) Western Visayas January 28, 1990-April 1991[17] 2. Numeriano Tanopo, Jr. (Pangasinan) Central Luzon April 1991-June 30, 1991 3. Mervin Encanto (Quezon City) Greater Manila 1993-1995 4. Raoul R. Angangco (Makati) Southern Luzon 1995-1997 5. Jose Aguila Grapilon (Biliran) Eastern Visayas 1997-1999 6.Arthur Lim (Zambasulta) Western Mindanao 1999-2001 7. Teofilo Pilando, Jr. (Kalinga Apayao) Northern Luzon 2001-2003 8. Jose Anselmo Cadiz (Camarines Sur) Bicolandia 2003-2005
	GR No. 155830 2012-08-15	NUMERIANO P. ABOBON v. FELICITAS ABATA ABOBON BERSAMIN, J.
First of all, a fundamental principle in land registration under the Torrens system is that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein.[12] The certificate of title thus becomes the best proof of ownership of a parcel of land;[13] hence, anyone who deals with property registered under the Torrens system may rely on the title and need not go beyond the title.[14] This reliance on the certificate of title rests on the doctrine of indefeasibility of the land title, which has long been well-settled in this jurisdiction. It is only when the acquisition of the title is attended with fraud or bad faith that the doctrine of indefeasibility finds no application.[15]
	GR No. 168105 2011-07-27	LAND BANK OF PHILIPPINES v. SEVERINO LISTANA VILLARAMA, JR., J.
It is a fundamental legal principle that 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 and law, and whether it be made by the court that rendered it or by the highest court of the land. The only exceptions to the general rule on finality of judgments are 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.[32] Indeed, litigation must end and terminate sometime and somewhere, even at the risk of occasional errors.[33]
	GR No. 178984 2009-08-19	ERLINDA MAPAGAY v. PEOPLE CHICO-NAZARIO, J.
Once a judgment attains finality, it becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by this Court.[34] Decisions that have long become final and executory cannot be annulled by courts, and the appellate court is deprived of jurisdiction to alter the trial court's final judgment.[35] This doctrine is founded on considerations of public policy and sound practice that, at the risk of occasional errors, judgments must become final at some point in time.[36]
	GR No. 163208 2008-08-13	HEIRS OF JUAN VALDEZ v. CA BRION, J.
Even granting that the first May 5, 2003 Resolution became final and executory, the rule on immutability of judgment does not apply in cases where what is to be modified or altered involves: (a) the correction of clerical errors; (b) the so-called nunc pro tunc entries which cause no prejudice to any party; (c) void judgments [such as a dismissal without prejudice that was not intended to be issued] and those where circumstances transpire after the finality that render the execution or enforcement, as in this case, of the judgment unjust or inequitable.[20] To be sure, the rule does not apply in cases where a supervening event - such as the mistake undisputably committed by the court (i.e., the unintended release of one of the resolutions, thus resulting in the conflict and confusion) - took place.[21]
	GR No. 147082 2008-01-28	HEIRS OF MAURA SO v. vs.LUCILA JOMOC OBLIOSCA NACHURA, J.
The doctrine of finality of judgment is grounded on the fundamental principle of public policy and sound practice that, at the risk of occasional error, the judgment of courts and the award of quasi-judicial agencies must become final on some definite date fixed by law.[24] 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 whenever circumstances transpire after the finality of the decision which render its execution unjust and inequitable.[25] Again, none of these exceptions is present in this case.
	GR No. 170099 2007-11-28	COLBY CONTSRUCTION v. NLRC CHICO-NAZARIO, J.
Petitioners' theory of substantial compliance totally transgresses the basic principle that the finality of a decision is a jurisdictional event that cannot be made to depend on the convenience of the party. To allow the party to determine at his discretion when to post an appeal bond, which is a necessary requisite in the perfection of an appeal, would in effect, unduly delay the running of the period for a decision to attain its finality, thereby completely negating the purpose of the rule on the completeness of service, which is to place the date of receipt of pleadings, judgments and processes beyond the power of the party being served to determine at his pleasure.[29]
	AM NO. RTJ-04-1840 2007-08-02	LAGCAO v. JUDGE IRENEO LEE GAKO CORONA, J.
We agree with the OCA that respondent had legal basis in issuing the writ in his March 27, 2000 resolution. It is true that complainants had in their favor a final and executory decision by the MTCC which had become immutable and unalterable.[33] However, one of the exceptions to the principle of immutability of final judgments is the existence of supervening events. Supervening events refer to facts which transpire or new circumstances which develop after the judgment acquires finality, rendering its execution unjust and inequitable.[34]
	GR NO. 158992 2007-01-26	REPUBLIC v. SPS. JOSE AND AMELIA LURIZ VELASCO, JR., J.
In the same manner, the Court in Sacdalan v. Court of Appeals affirmed the reinstatement of an appeal previously dismissed for failure to pay the docket fees. It held that the appeal was dismissed not because the appellant lacked interest in the case, but because of lack of proper notice. Thus, it considered the reinstatement of the appeal as just and proper because the "interest of substantial justice far outweighs whatever negligence"[14] was committed.
	GR NO. 135817 2006-11-30	REYNALDO RODRIGUEZ v. CONCORDIA ONG LIM CALLEJO, SR., J.
Petitioners cannot raise the defense of indefeasibility of a Torrens title with respect to TCT No. T-168607 because "the principle of indefeasibility of a Torrens title does not apply where fraud attended the issuance of the title. The Torrens title does not furnish a shield for fraud."[21] They cannot deny any knowledge of the fraud that attended the transactions involving the subject lots, including their acquisition thereof. Stated differently, petitioners cannot claim that they were purchasers in good faith and for value because the transactions involving the subject lots were so replete with badges of fraud and irregularities that should have put them on guard about the defects in the respective titles of Frisco Gudani and Eduardo Victa.
	GR NO. 129165 2006-10-30	SPS. RODRIGO COLOSO AND ELISA COLOSO v. SECRETARY ERNESTO V. GARILAO VELASCO, JR., J.
In Sacdalan v. Court of Appeals, we ruled that "[a] decision that 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."[24]
	GR NO. 145420 2006-09-19	A. RAFAEL C. DINGLASAN JR. v. CA CHICO-NAZARIO, J.
"Sec. 10. Entry of judgments and final resolutions. - If no appeal or motion for new trial or reconsideration is filed within the time provided in these Rules, the judgment or final resolution shall forthwith be entered by the clerk in the book of entries of judgments. The date when the judgment or final resolution becomes executory shall be deemed as the date of its entry. The record shall contain the dispositive part of the judgment or final resolution and shall be signed by the clerk, with a certificate that such judgment or final resolution has become final and executory. After the judgment or final resolution is entered in the entries of judgment, the case shall be laid to rest. A decision that acquired finality becomes immutable and unalterable and it 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.[24]
	GR NO. 159520 2006-09-19	FELISA L. PEÑA v. GOVERNMENT SERVICE INSURANCE SYSTEM CHICO-NAZARIO, J.
The rule on finality of decisions, orders or resolutions of a judicial, quasi-judicial or administrative body is "not a question of technicality but of substance and merit," the underlying consideration therefore, being the protection of the substantive rights of the winning party.[39] Nothing is more settled in law than that 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.[40]
	ADM CASE NO. 5649 2006-01-27	DANDY V. QUIJANO v. GEOBEL A. BARTOLABAC TINGA, J.
Once the case is decided with finality, the controversy is settled and the matter is laid to rest. The prevailing party is entitled to enjoy the fruits of his victory while the other party is obliged to respect the court's verdict and to comply with it. We reiterate our pronouncement in Salicdan v. Court of Appeals: [29]
	GR NO. 127967 2005-12-14	FEDERATED REALTY CORPORATION v. CA TINGA, J.
Time and again, we have upheld the fundamental principle in land registration that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein.[30] It becomes the best proof of ownership of a parcel of land.[31] One who deals with property registered under the Torrens system may rely on the title and need not go beyond the same.[32] Such principle of indefeasibility has long been well-settled in this jurisdiction and it is only when the acquisition of the title is attended with fraud or bad faith that the doctrine finds no application.[33]
	GR NO. 158971 2005-08-25	MARIANO Y. SIY v. NLRC CORONA, J.
Once a case is decided with finality, the controversy is settled and the matter is laid to rest. The prevailing party is entitled to enjoy the fruits of his victory while the other party is obliged to respect the court's verdict and to comply with it. We reiterate our pronouncement in Sacdalan v. Court of Appeals:[18]
	GR NO. 125585 2005-06-08	HEIRS OF EDUARDO MANLAPAT v. CA TINGA, J.
Time and again, this Court has ruled that the principle of indefeasibility of a Torrens title does not apply where fraud attended the issuance of the title, as was conclusively established in this case. The Torrens title does not furnish a shied for fraud.[47] Registration does not vest title. It is not a mode of acquiring ownership but is merely evidence of such title over a particular property. It does not give the holder any better right than what he actually has, especially if the registration was done in bad faith. The effect is that it is as if no registration was made at all.[48] In fact, this Court has ruled that a decree of registration cut off or extinguished a right acquired by a person when such right refers to a lien or encumbrance on the land not to the right of ownership thereof which was not annotated on the certificate of title issued thereon.[49]
	GR NO. 146006 2005-04-22	JOSE C. LEE v. RTC OF QUEZON CITY CORONA, 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 whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable. [26]

PAULINO SACDALAN v. CA