The Supreme Court in Karen Go v. Lamberto Echavez reiterated the principle of immutability of final judgments, emphasizing that a decision, once final, can no longer be altered, amended, or reversed, regardless of perceived errors of fact or law. The court clarified that exceptions to this rule are limited to correcting clerical errors, making nunc pro tunc entries, addressing void judgments, and considering supervening events. This ruling reinforces the stability and conclusiveness of judicial decisions, protecting the rights vested by a final judgment.

Truck Troubles: Can a Final Judgment on Damages Be Reopened?

This case arose from a dispute over a Fuso Dropside Truck initially leased to Nick Carandang by Karen Go’s company, Kargo Enterprises. Carandang, in violation of the lease agreement, sold the truck to Lamberto Echavez. Go filed a replevin suit to recover the truck, and Echavez counterclaimed for damages, alleging lost income due to the truck’s seizure. The Regional Trial Court (RTC) ruled in favor of Echavez, awarding him P10,000.00 per week as actual damages from the date of the truck’s seizure. Go appealed, but her appeal was dismissed, rendering the RTC judgment final.

Subsequently, Go sought to clarify the judgment, arguing that the award of damages would unjustly enrich Echavez. The RTC denied the motion, and the Court of Appeals (CA) affirmed, leading Go to elevate the case to the Supreme Court. At the heart of the legal matter was whether the final judgment could be modified or clarified, given Go’s claims of conflicting rulings and unjust enrichment.

The Supreme Court affirmed the CA’s decision, emphasizing the doctrine of immutability of final judgments. Once a judgment becomes final, it is considered conclusive and can no longer be altered, amended, or reversed. The Court cited Navarro v. Metrobank, stating:

x x x At that point, the Judgment had become immutable, and hence could no longer be changed, revised, amended, or reversed.

This principle ensures stability and respect for judicial decisions. The Court acknowledged limited exceptions to this rule, including:

• Correction of clerical errors
• Making nunc pro tunc entries (correcting omissions in the record)
• Attacking a void judgment
• Considering supervening events that render execution unjust

The Court analyzed whether any of these exceptions applied to Go’s case. Regarding clerical errors, the Court clarified that such errors must be plainly due to inadvertence or negligence and cannot be used to add terms or orders that the court never adjudged. In this case, the award of damages was not a clerical error, as it reflected Echavez’s claim for unrealized income.

The Court also rejected the applicability of nunc pro tunc entry, explaining that it is intended to make the record speak the truth, not to introduce new findings of facts or law. Go’s argument that the RTC erroneously assumed continuous use of the truck for three years would require new factual findings, which are not permissible in a nunc pro tunc entry. Importantly, a nunc pro tunc entry cannot prejudice either party.

The Court addressed the issue of void judgments, reiterating that a void judgment has no legal effect and can be attacked collaterally. However, the party seeking to nullify the judgment must demonstrate that it is utterly void on its face. The Court found that the RTC judgment complied with the requisites of a valid decision and due process, thus, it was not void.

Furthermore, the Court considered whether supervening events justified modifying the judgment. Supervening events are circumstances that transpire after the decision’s finality, rendering its execution unjust. However, Go failed to allege or prove any such event. While Go delivered a replacement truck to Echavez during partial execution, this did not recompense him for the unrealized income he suffered since the truck’s seizure.

The Supreme Court also addressed Go’s argument of unjust enrichment. While the Court acknowledged that the award of damages might be considered exorbitant, it emphasized that variance in opinion does not render the award void. Citing Nunal v. CA, the Court reiterated that a final judgment may no longer be modified, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law. The Court also pointed out that Go never alleged that the award is vague.

The Court underscored that Echavez was entitled to a writ of execution as a matter of right, and the RTC did not abuse its discretion in issuing it. Finally, the Court cautioned lawyers against filing frivolous petitions that waste the court’s time, noting that such actions could result in penalties under A.M. No. 07-7-12-SC.

FAQs

What was the key issue in this case?	The central issue was whether a final and executory judgment awarding damages could be modified or clarified based on arguments of conflicting rulings and unjust enrichment.
What is the principle of immutability of final judgments?	This principle states that a decision, once final, can no longer be altered, amended, or reversed, ensuring stability and respect for judicial decisions.
What are the exceptions to the principle of immutability?	The exceptions include correcting clerical errors, making nunc pro tunc entries, addressing void judgments, and considering supervening events.
What is a clerical error in the context of judgments?	A clerical error is an error or mistake due to inadvertence or negligence that results in the record failing to correctly represent the court’s decision.
What is a nunc pro tunc entry?	A nunc pro tunc entry is used to put on record an act that the court performed but omitted from the record, not to introduce new findings.
What makes a judgment void?	A void judgment lacks legal effect and does not divest rights. It can be attacked collaterally, but must be proven utterly void on its face.
What are supervening events?	Supervening events are circumstances that occur after a decision’s finality, rendering its execution unjust and warranting reconsideration.
What was the basis for the damages awarded to Echavez?	The damages were based on Echavez’s counterclaim for unrealized income due to the seizure of the truck, which was supported by documentary evidence.
Did the delivery of a replacement truck affect the judgment?	No, the delivery of a replacement truck did not affect the judgment because it did not compensate Echavez for the unrealized income he suffered.

This case serves as a crucial reminder of the importance of adhering to procedural rules and exhausting all available remedies during the initial stages of litigation. Once a judgment becomes final, the window for challenging its factual or legal basis is virtually closed, underscoring the need for diligence and thoroughness in pursuing one’s legal claims.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Karen Go v. Lamberto Echavez, G.R. No. 174542, August 03, 2015