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APO FRUITS CORPORATION v. CA

This case has been cited 6 times or more.

2014-06-18
BRION, J.
Even assuming that the NLRC has jurisdiction over Jordan's "memorandum of appeal", we agree with the CA that the NLRC gravely abused its discretion in substantively altering the dispositive part of the May 27, 2008 decision. While tribunals and courts may correct clerical errors in a judgment that has attained finality, its final and executory character precludes these bodies from substantively altering its dispositive part, except: (1) in cases of void judgments, and (2) whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable.[42] As a rule, a definitive final judgment, however erroneous, is no longer subject to substantial change or revision.[43]
2013-09-02
PERLAS-BERNABE, J.
It is well-settled that under the doctrine of immutability of judgment, 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.[29] Any act which violates this principle must immediately be struck down.[30] This doctrine has a two-fold purpose, namely: (a) to avoid delay in the administration of justice and thus, procedurally, to make orderly the discharge of judicial business; and (b) to put an end to judicial controversies, at the risk of occasional errors, which is precisely why courts exist.[31] Controversies cannot drag on indefinitely. The rights and obligations of every litigant must not hang in suspense for an indefinite period of time.[32] The doctrine is not a mere technicality to be easily brushed aside, but a matter of public policy as well as a time-honored principle of procedural law.[33]
2013-07-01
REYES, J.
Being a final judgment, the dispositions and conclusions therein have become immutable and unalterable not only as against the parties but even the courts.  This is known as the doctrine of immutability of judgments which espouses that 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.[27]  The significance of this rule was emphasized in Apo Fruits Corporation v. Court of Appeals,[28] to wit: The reason for the rule is that if, on the application of one party, the court could change its judgment to the prejudice of the other, it could thereafter, on application of the latter, again change the judgment and continue this practice indefinitely.  The equity of a particular case must yield to the overmastering need of certainty and unalterability of judicial pronouncements.
2012-09-24
BERSAMIN, J.
The attitude of judicial reluctance towards the annulment of a judgment, final order or final resolution is understandable, for the remedy disregards the time-honored doctrine of immutability and unalterability of final judgments, a solid corner stone in the dispensation of justice by the courts. The doctrine of immutability and unalterability serves a two-fold purpose, namely: (a) to avoid delay in the administration of justice and thus, procedurally, to make orderly the discharge of judicial business; and (b) to put an end to judicial controversies, at the risk of occasional errors, which is precisely why the courts exist.[12] As to the first, a judgment that has acquired finality becomes immutable and unalterable and is no longer to be modified in any respect even if the modification is meant to correct an erroneous conclusion of fact or of law, and whether the modification is made by the court that rendered the decision or by the highest court of the land.[13] As to the latter, controversies cannot drag on indefinitely because fundamental considerations of public policy and sound practice demand that the rights and obligations of every litigant must not hang in suspense for an indefinite period of time.[14]
2012-08-23
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.
2009-12-21
VELASCO JR., J.
After the effectivity of RA 9009, the Lower House of the 12th Congress adopted in July 2001 House (H.) Joint Resolution No. 29[24] which, as its title indicated, sought to exempt from the income requirement prescribed in RA 9009 the 24 municipalities whose conversions into cities were not acted upon during the previous Congress. The 12th Congress ended without the Senate approving H. Joint Resolution No. 29.