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GR No. 181949

2014-04-23

HEIRS OF FRANCISCO BIHAG v. HEIRS OF NICASIO BATHAN

DEL CASTILLO, J.

The doctrine of finality of judgment dictates that, at the risk of occasional errors, judgments or orders must become final at some point in time.[1]

GR No. 183858

2013-04-17

HOLY TRINITY REALTY DEVELOPMENT CORPORATION v. SPS. CARLOS AND ELIZABETH ABACAN

SERENO, C.J.

Turning now to the merits of the petition, we find that the CA committed reversible error in ruling that the MTCC had no jurisdiction over the unlawful detainer case. What was before it was a petition for certiorari against the MTCC's denial of respondents' motion to quash. The petition was not directed at the MTCC's Consolidated Decision of 25 May 2005, nor could it be, because a Rule 65 petition for certiorari must be filed not later than 60 days from notice of the judgment.[31] Since respondents failed to timely appeal the Consolidated Decision, it has long attained finality and has become immutable and unalterable pursuant to the doctrine on finality of judgment.[32] Thus, as respondents' sole argument in their motion to quash was the existence of a material supervening event, and as the MTCC's denial of their motion was premised on the conclusion that their subsequent acquisition of ownership was not a supervening event, the resolution of the present case should be limited to that issue.

GR No. 197003

2013-02-11

NERIE C. SERRANO v. AMBASSADOR HOTEL

VELASCO JR., J.

Nothing is more settled in law than that once a judgment attains finality it thereby 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 the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case. The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by settling justiciable controversies with finality.[44] (Emphasis supplied.)

GR No. 188376

2011-12-14

LAND BANK OF PHILIPPINES v. FEDERICO SUNTAY

BERSAMIN, J.

In effect, Land Bank v. Suntay (G.R. No. 157903) set aside the decision of RARAD Miñas dated January 24, 2000 fixing the just compensation. The finality of the judgment in Land Bank v. Suntay (G.R. No. 157903) meant that the decrees thereof could no longer be altered, modified, or reversed even by the Court en banc. Nothing is more settled in law than that a judgment, once it attains finality, becomes immutable and unalterable, and can 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 the highest court of the land.[78] This rule rests on the principle that all litigation must come to an end, however unjust the result of error may appear; otherwise, litigation will become even more intolerable than the wrong or injustice it is designed to correct.[79]

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. 175393

2009-12-18

GOVERNMENT SERVICE INSURANCE SYSTEM v. RTC OF PASIG CITY

LEONARDO-DE CASTRO, J.

Nothing is more settled in law than that once a judgment attains finality it thereby 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 the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case. The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by setting justiciable controversies with finality (Gallardo-Corro v. Gallardo)[63].

GR No. 150664

2009-09-03

VICENTE DACANAY v. RAPHAEL YRASTORZA

CORONA, J.

Once a judgment attains finality, it becomes immutable and unalterable. A final and executory judgment 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 the highest court of the land.[29] This is the doctrine of finality of judgment. It is grounded on fundamental considerations of public policy and sound practice that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law.[30] Otherwise, there will be no end to litigations, thus negating the main role of courts of justice to assist in the enforcement of the rule of law and the maintenance of peace and order by settling justiciable controversies with finality.[31]

GR No. 158270

2008-07-21

LAND BANK OF PHILIPPINES v. HERMIN ARCEO

REYES, R.T., J.

Notwithstanding the procedural lapse of the appellate court, We still affirm the RTC decision for having attained finality. The doctrine of finality of judgments provides that once judgment had become final and executory, it becomes immutable and can no longer be amended or modified. In Gallardo-Corro v. Gallardo, [15] this Court held: Nothing is more settled in law than that once a judgment attains finality it thereby 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 the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case. The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by setting justiciable controversies with finality.[16] In the recent case of Social Security System v. Isip,[17] this Court reiterated the long established doctrine, thus:

GR No. 161777

2008-05-07

DOMINIC GRIFFITH v. ANGELITO ESTUR

CARPIO, J.

Labor Arbiter Layawen's decision is already final and executory and can no longer be the subject of an appeal. Thus, petitioner is bound by the decision and can no longer impugn the same.[8] Indeed, well-settled is the rule that a decision that has attained finality can no longer be modified even if the modification is meant to correct erroneous conclusions of fact or law.[9] The doctrine of finality of judgment is explained in Gallardo-Corro v. Gallardo:[10]

GR No. 163360

2007-06-08

HEIRS OF IGMEDIO* MAGLAQUE v. CA

QUISUMBING, J.

Nothing is more settled in law than that once a judgment attains finality it thereby 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 the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case. The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by settling justiciable controversies with finality.[28] The case of Heirs of the Late Faustina Adalid enunciates the reason for the rule of res judicata:The doctrine of res judicata is a rule which pervades every well-regulated system of jurisprudence and is founded upon two grounds embodied in various maxims of the common law, namely: (1) public policy and necessity, which makes it to the interest of the State that there should be an end to litigation - republicae ut sit litium, and (2) the hardship on the individual that he should be vexed twice for the same cause - nemo debet bis vexari et eadem causa. A contrary doctrine would subject the public peace and quiet to the will and neglect of individuals and prefer the gratification of the litigious disposition on the part of suitors to the preservation of the public tranquility and happiness.[29] Indeed, it has been well said that this maxim is more than a mere rule of law, more even than an important principle of public policy, and that it is a fundamental concept in the organization of every jural society, for not only does it ward off endless litigation, it ensures the stability of judgment, and guards against inconsistent decisions on the same set of facts.[30]

GR No. 157616

2005-07-22

ISIDRO PEREZ v. CA

CALLEJO, SR., J.

Indeed, absolute identity of parties is not a condition sine qua non for the application of res judicata. It is sufficient that there is a shared identity of interest.[36] The rule is that, even if new parties are found in the second action, res judicata still applies if the party against whom the judgment is offered in evidence was a party in the first action; otherwise, a case can always be renewed by the mere expedience of joining new parties in the new suit.[37]

GR No. 132076

2003-07-22

ROBERTO U. GENOVA v. LEVITA DE CASTRO

YNARES-SANTIAGO, J.

Petitioner likewise contends that respondent was guilty of forum shopping. The test to determine whether a party violated the rule against forum shopping is whether the elements of litis pendentia are present, or whether a final judgment in one case will amount to res judicata in another.[21] Accordingly, there is res judicata where the following four essential conditions concur, viz: (1) there must be a final judgment or order; (2) the court rendering it must have jurisdiction over the subject matter and the parties; (3) it must be a judgment or order on the merits; and (4) there must be, between the two cases, identity of parties, subject matter and causes of action.[22]

AM No. RTJ-02-1672

2002-01-30

MICHAEL T. VISTAN v. JUDGE ADORACION G. ANGELES RTC

PUNO, J.

Section 3, Rule 17 of the Rules of Court provides that if the plaintiff fails to comply with any order of the court, the action may be dismissed upon motion of the defendant or upon the court's own motion, and the dismissal shall have the effect of an adjudication on the merits, unless otherwise provided by the court.[7]

	GR No. 181949 2014-04-23	HEIRS OF FRANCISCO BIHAG v. HEIRS OF NICASIO BATHAN DEL CASTILLO, J.
The doctrine of finality of judgment dictates that, at the risk of occasional errors, judgments or orders must become final at some point in time.[1]
	GR No. 183858 2013-04-17	HOLY TRINITY REALTY DEVELOPMENT CORPORATION v. SPS. CARLOS AND ELIZABETH ABACAN SERENO, C.J.
Turning now to the merits of the petition, we find that the CA committed reversible error in ruling that the MTCC had no jurisdiction over the unlawful detainer case. What was before it was a petition for certiorari against the MTCC's denial of respondents' motion to quash. The petition was not directed at the MTCC's Consolidated Decision of 25 May 2005, nor could it be, because a Rule 65 petition for certiorari must be filed not later than 60 days from notice of the judgment.[31] Since respondents failed to timely appeal the Consolidated Decision, it has long attained finality and has become immutable and unalterable pursuant to the doctrine on finality of judgment.[32] Thus, as respondents' sole argument in their motion to quash was the existence of a material supervening event, and as the MTCC's denial of their motion was premised on the conclusion that their subsequent acquisition of ownership was not a supervening event, the resolution of the present case should be limited to that issue.
	GR No. 197003 2013-02-11	NERIE C. SERRANO v. AMBASSADOR HOTEL VELASCO JR., J.
Nothing is more settled in law than that once a judgment attains finality it thereby 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 the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case. The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by settling justiciable controversies with finality.[44] (Emphasis supplied.)
	GR No. 188376 2011-12-14	LAND BANK OF PHILIPPINES v. FEDERICO SUNTAY BERSAMIN, J.
In effect, Land Bank v. Suntay (G.R. No. 157903) set aside the decision of RARAD Miñas dated January 24, 2000 fixing the just compensation. The finality of the judgment in Land Bank v. Suntay (G.R. No. 157903) meant that the decrees thereof could no longer be altered, modified, or reversed even by the Court en banc. Nothing is more settled in law than that a judgment, once it attains finality, becomes immutable and unalterable, and can 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 the highest court of the land.[78] This rule rests on the principle that all litigation must come to an end, however unjust the result of error may appear; otherwise, litigation will become even more intolerable than the wrong or injustice it is designed to correct.[79]
	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. 175393 2009-12-18	GOVERNMENT SERVICE INSURANCE SYSTEM v. RTC OF PASIG CITY LEONARDO-DE CASTRO, J.
Nothing is more settled in law than that once a judgment attains finality it thereby 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 the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case. The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by setting justiciable controversies with finality (Gallardo-Corro v. Gallardo)[63].
	GR No. 150664 2009-09-03	VICENTE DACANAY v. RAPHAEL YRASTORZA CORONA, J.
Once a judgment attains finality, it becomes immutable and unalterable. A final and executory judgment 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 the highest court of the land.[29] This is the doctrine of finality of judgment. It is grounded on fundamental considerations of public policy and sound practice that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law.[30] Otherwise, there will be no end to litigations, thus negating the main role of courts of justice to assist in the enforcement of the rule of law and the maintenance of peace and order by settling justiciable controversies with finality.[31]
	GR No. 158270 2008-07-21	LAND BANK OF PHILIPPINES v. HERMIN ARCEO REYES, R.T., J.
Notwithstanding the procedural lapse of the appellate court, We still affirm the RTC decision for having attained finality. The doctrine of finality of judgments provides that once judgment had become final and executory, it becomes immutable and can no longer be amended or modified. In Gallardo-Corro v. Gallardo, [15] this Court held: Nothing is more settled in law than that once a judgment attains finality it thereby 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 the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case. The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by setting justiciable controversies with finality.[16] In the recent case of Social Security System v. Isip,[17] this Court reiterated the long established doctrine, thus:
	GR No. 161777 2008-05-07	DOMINIC GRIFFITH v. ANGELITO ESTUR CARPIO, J.
Labor Arbiter Layawen's decision is already final and executory and can no longer be the subject of an appeal. Thus, petitioner is bound by the decision and can no longer impugn the same.[8] Indeed, well-settled is the rule that a decision that has attained finality can no longer be modified even if the modification is meant to correct erroneous conclusions of fact or law.[9] The doctrine of finality of judgment is explained in Gallardo-Corro v. Gallardo:[10]
	GR No. 163360 2007-06-08	HEIRS OF IGMEDIO* MAGLAQUE v. CA QUISUMBING, J.
Nothing is more settled in law than that once a judgment attains finality it thereby 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 the highest court of the land. Just as the losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his case. The doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice, and that, at the risk of occasional errors, the judgments or orders of courts must become final at some definite time fixed by law; otherwise, there would be no end to litigations, thus setting to naught the main role of courts of justice which is to assist in the enforcement of the rule of law and the maintenance of peace and order by settling justiciable controversies with finality.[28] The case of Heirs of the Late Faustina Adalid enunciates the reason for the rule of res judicata:The doctrine of res judicata is a rule which pervades every well-regulated system of jurisprudence and is founded upon two grounds embodied in various maxims of the common law, namely: (1) public policy and necessity, which makes it to the interest of the State that there should be an end to litigation - republicae ut sit litium, and (2) the hardship on the individual that he should be vexed twice for the same cause - nemo debet bis vexari et eadem causa. A contrary doctrine would subject the public peace and quiet to the will and neglect of individuals and prefer the gratification of the litigious disposition on the part of suitors to the preservation of the public tranquility and happiness.[29] Indeed, it has been well said that this maxim is more than a mere rule of law, more even than an important principle of public policy, and that it is a fundamental concept in the organization of every jural society, for not only does it ward off endless litigation, it ensures the stability of judgment, and guards against inconsistent decisions on the same set of facts.[30]
	GR No. 157616 2005-07-22	ISIDRO PEREZ v. CA CALLEJO, SR., J.
Indeed, absolute identity of parties is not a condition sine qua non for the application of res judicata. It is sufficient that there is a shared identity of interest.[36] The rule is that, even if new parties are found in the second action, res judicata still applies if the party against whom the judgment is offered in evidence was a party in the first action; otherwise, a case can always be renewed by the mere expedience of joining new parties in the new suit.[37]
	GR No. 132076 2003-07-22	ROBERTO U. GENOVA v. LEVITA DE CASTRO YNARES-SANTIAGO, J.
Petitioner likewise contends that respondent was guilty of forum shopping. The test to determine whether a party violated the rule against forum shopping is whether the elements of litis pendentia are present, or whether a final judgment in one case will amount to res judicata in another.[21] Accordingly, there is res judicata where the following four essential conditions concur, viz: (1) there must be a final judgment or order; (2) the court rendering it must have jurisdiction over the subject matter and the parties; (3) it must be a judgment or order on the merits; and (4) there must be, between the two cases, identity of parties, subject matter and causes of action.[22]
	AM No. RTJ-02-1672 2002-01-30	MICHAEL T. VISTAN v. JUDGE ADORACION G. ANGELES RTC PUNO, J.
Section 3, Rule 17 of the Rules of Court provides that if the plaintiff fails to comply with any order of the court, the action may be dismissed upon motion of the defendant or upon the court's own motion, and the dismissal shall have the effect of an adjudication on the merits, unless otherwise provided by the court.[7]

EMMA GALLARDO-CORRO v. EFREN DON L. GALLARDO