Lawyerly

GR No. 211140

2016-01-12

LORD ALLAN JAY Q. VELASCO v. SPEAKER FELICIANO R. BELMONTE

LEONARDO-DE CASTRO, J.

As to the issues presented for resolution, Reyes questions the jurisdiction of the Court over Quo Warranto cases involving Members of the House of Representatives. She posits that "even if the Petition for Mandamus be treated as one of Quo Warranto, it is still dismissible for lack of jurisdiction and absence of a clear legal right on the part of [Velasco] "[29] She argues that numerous jurisprudence have already ruled that it is the House of Representatives Electoral Tribunal that has the sole and exclusive jurisdiction over all contests relating to the election, returns and qualifications of Members of the House of Representatives. Moreover, she insists that there is also an abundance of case law that categorically states that the COMELEC is divested of jurisdiction upon her proclamation as the winning candidate, as, in fact, the HRET had already assumed jurisdiction over quo warranto cases[30] filed against Reyes by several individuals.

GR No. 194751

2014-11-26

AURORA N. DE PEDRO v. ROMASAN DEVELOPMENT CORPORATION

LEONEN, J.

This court explained in FGU Insurance Corporation v. Regional Trial Court[131] the doctrine of finality of judgment, thus: Under the doctrine of finality of judgment or 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. Any act which violates this principle must immediately be struck down.[132]

GR No. 197486

2014-09-10

RENATO L. DELFINO v. AVELINO K. ANASAO

VILLARAMA, JR., J.

There are, however, exceptions to the general rule, namely: (1) the correction of clerical errors; (2) the so-called nunc pro tunc entries which cause no prejudice to any party; (3) void judgments; and (4) whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable.[35] The exception to the doctrine of immutability of judgment has been applied in several cases in order to serve substantial justice.[36]

GR No. 194560

2014-06-11

NESTOR T. GADRINAB v. NORA T. SALAMANCA

LEONEN, J.

This court explained in FGU Insurance Corporation v. Regional Trial Court[60] the doctrine of finality of judgment: Under the doctrine of finality of judgment or 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. Any act which violates this principle must immediately be struck down.[61]

GR No. 180427

2013-09-30

CRISANTA GUIDO-ENRIQUEZ v. ALICIA I. VICTORINO

PERALTA, J.

The Court is not persuaded. As the CA had correctly ruled, the assailed August 15, 1988 Decision of the RTC had already become final and executory and under the doctrine of finality of judgment or 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.[7] Any act which violates this principle must immediately be struck down.[8] While there are recognized exceptions to this doctrine,[9] petitioner failed to prove that the instant case is among them.

GR No. 162226

2013-09-02

SANGGUNIANG BARANGAY OF PANGASUGAN v. EXPLORATION PERMIT APPLICATION OF PHILIPPINE NATIONAL OIL COMPANY

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]

GR No. 192727

2013-01-09

RAUL B. ESCALANTE v. PEOPLE

REYES, J.

Nevertheless, considering that the CA's June 24, 2008 Decision and March 4, 2009 Resolution had already attained finality on account of the petitioner's failure to timely file a petition for review on Certiorari under Rule 45, the Court may no longer modify the penalty imposed by the lower courts no matter how obvious the error may be. "Under the doctrine of finality of judgment or 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."[32]

GR Nos. 180880-81

2012-09-18

KEPPEL CEBU SHIPYARD v. PIONEER INSURANCE

MENDOZA, J.

Verily, "under the doctrine of finality of judgment or 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."[28] This rule notwithstanding, the Court En Banc had re-opened and accepted several cases for review and reevaluation for special and compelling reasons. Among these cases were Manotok IV v. Heirs of Homer L. Barque,[29] Apo Fruits Corporation and Hijo Plantation, Inc. v. Land Bank of the Philippines,[30] League of Cities of the Philippines v. Commission on Elections,[31] and Navarro v. Ermita.[32]

GR No. 171182

2012-08-23

UNIVERSITY OF PHILIPPINES v. AGUSTIN S. DIZON

BERSAMIN, J.

It is true that a decision that has attained finality becomes immutable and unalterable, and cannot be modified in any respect,[87] even if the modification is meant to correct erroneous conclusions of fact and law, and whether the modification is made by the court that rendered it or by this Court as the highest court of the land.[88] Public policy dictates that once a judgment becomes final, executory and unappealable, the prevailing party should not be deprived of the fruits of victory by some subterfuge devised by the losing party. Unjustified delay in the enforcement of such judgment sets at naught the role and purpose of the courts to resolve justiciable controversies with finality.[89] Indeed, all litigations must at some time end, even at the risk of occasional errors.

GR No. 194653

2012-02-08

ANTONIO MENDOZA v. FIL-HOMES REALTY DEVELOPMENT CORPORATION

REYES, J.

The issue presented by the instant case is not novel. In FGU Insurance Corporation v. Regional Trial Court of Makati City,Branch 66, [9] we explained that, although a decision that has acquired finality becomes immutable, unalterable, and may no longer be modified in any respect, still there are exceptions to the said rule. Thus: Fundamental is the rule that where the judgment of a higher court has become final and executory and has been returned to the lower court, the only function of the latter is the ministerial act of carrying out the decision and issuing the writ of execution. In addition, a final and executory judgment can no longer be amended by adding thereto a relief not originally included. In short, once a judgment becomes final, the winning party is entitled to a writ of execution and the issuance thereof becomes a court's ministerial duty. The lower court cannot vary the mandate of the superior court or reexamine it for any other purpose other than execution; much less may it review the same upon any matter decided on appeal or error apparent; nor intermeddle with it further than to settle so much as has been demanded.

	GR No. 211140 2016-01-12	LORD ALLAN JAY Q. VELASCO v. SPEAKER FELICIANO R. BELMONTE LEONARDO-DE CASTRO, J.
As to the issues presented for resolution, Reyes questions the jurisdiction of the Court over Quo Warranto cases involving Members of the House of Representatives. She posits that "even if the Petition for Mandamus be treated as one of Quo Warranto, it is still dismissible for lack of jurisdiction and absence of a clear legal right on the part of [Velasco] "[29] She argues that numerous jurisprudence have already ruled that it is the House of Representatives Electoral Tribunal that has the sole and exclusive jurisdiction over all contests relating to the election, returns and qualifications of Members of the House of Representatives. Moreover, she insists that there is also an abundance of case law that categorically states that the COMELEC is divested of jurisdiction upon her proclamation as the winning candidate, as, in fact, the HRET had already assumed jurisdiction over quo warranto cases[30] filed against Reyes by several individuals.
	GR No. 194751 2014-11-26	AURORA N. DE PEDRO v. ROMASAN DEVELOPMENT CORPORATION LEONEN, J.
This court explained in FGU Insurance Corporation v. Regional Trial Court[131] the doctrine of finality of judgment, thus: Under the doctrine of finality of judgment or 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. Any act which violates this principle must immediately be struck down.[132]
	GR No. 197486 2014-09-10	RENATO L. DELFINO v. AVELINO K. ANASAO VILLARAMA, JR., J.
There are, however, exceptions to the general rule, namely: (1) the correction of clerical errors; (2) the so-called nunc pro tunc entries which cause no prejudice to any party; (3) void judgments; and (4) whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable.[35] The exception to the doctrine of immutability of judgment has been applied in several cases in order to serve substantial justice.[36]
	GR No. 194560 2014-06-11	NESTOR T. GADRINAB v. NORA T. SALAMANCA LEONEN, J.
This court explained in FGU Insurance Corporation v. Regional Trial Court[60] the doctrine of finality of judgment: Under the doctrine of finality of judgment or 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. Any act which violates this principle must immediately be struck down.[61]
	GR No. 180427 2013-09-30	CRISANTA GUIDO-ENRIQUEZ v. ALICIA I. VICTORINO PERALTA, J.
The Court is not persuaded. As the CA had correctly ruled, the assailed August 15, 1988 Decision of the RTC had already become final and executory and under the doctrine of finality of judgment or 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.[7] Any act which violates this principle must immediately be struck down.[8] While there are recognized exceptions to this doctrine,[9] petitioner failed to prove that the instant case is among them.
	GR No. 162226 2013-09-02	SANGGUNIANG BARANGAY OF PANGASUGAN v. EXPLORATION PERMIT APPLICATION OF PHILIPPINE NATIONAL OIL COMPANY 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]
	GR No. 192727 2013-01-09	RAUL B. ESCALANTE v. PEOPLE REYES, J.
Nevertheless, considering that the CA's June 24, 2008 Decision and March 4, 2009 Resolution had already attained finality on account of the petitioner's failure to timely file a petition for review on Certiorari under Rule 45, the Court may no longer modify the penalty imposed by the lower courts no matter how obvious the error may be. "Under the doctrine of finality of judgment or 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."[32]
	GR Nos. 180880-81 2012-09-18	KEPPEL CEBU SHIPYARD v. PIONEER INSURANCE MENDOZA, J.
Verily, "under the doctrine of finality of judgment or 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."[28] This rule notwithstanding, the Court En Banc had re-opened and accepted several cases for review and reevaluation for special and compelling reasons. Among these cases were Manotok IV v. Heirs of Homer L. Barque,[29] Apo Fruits Corporation and Hijo Plantation, Inc. v. Land Bank of the Philippines,[30] League of Cities of the Philippines v. Commission on Elections,[31] and Navarro v. Ermita.[32]
	GR No. 171182 2012-08-23	UNIVERSITY OF PHILIPPINES v. AGUSTIN S. DIZON BERSAMIN, J.
It is true that a decision that has attained finality becomes immutable and unalterable, and cannot be modified in any respect,[87] even if the modification is meant to correct erroneous conclusions of fact and law, and whether the modification is made by the court that rendered it or by this Court as the highest court of the land.[88] Public policy dictates that once a judgment becomes final, executory and unappealable, the prevailing party should not be deprived of the fruits of victory by some subterfuge devised by the losing party. Unjustified delay in the enforcement of such judgment sets at naught the role and purpose of the courts to resolve justiciable controversies with finality.[89] Indeed, all litigations must at some time end, even at the risk of occasional errors.
	GR No. 194653 2012-02-08	ANTONIO MENDOZA v. FIL-HOMES REALTY DEVELOPMENT CORPORATION REYES, J.
The issue presented by the instant case is not novel. In FGU Insurance Corporation v. Regional Trial Court of Makati City,Branch 66, [9] we explained that, although a decision that has acquired finality becomes immutable, unalterable, and may no longer be modified in any respect, still there are exceptions to the said rule. Thus: Fundamental is the rule that where the judgment of a higher court has become final and executory and has been returned to the lower court, the only function of the latter is the ministerial act of carrying out the decision and issuing the writ of execution. In addition, a final and executory judgment can no longer be amended by adding thereto a relief not originally included. In short, once a judgment becomes final, the winning party is entitled to a writ of execution and the issuance thereof becomes a court's ministerial duty. The lower court cannot vary the mandate of the superior court or reexamine it for any other purpose other than execution; much less may it review the same upon any matter decided on appeal or error apparent; nor intermeddle with it further than to settle so much as has been demanded.

FGU INSURANCE CORPORATION v. RTC OF MAKATI CITY