The Supreme Court reiterated the principle of finality of judgments, emphasizing that final and executory judgments are immutable and unalterable, even if there are grounds for correction. This principle was highlighted in the case involving Maria Cristina Sergio and Julius Lacanilao, where the prosecution sought to supplement a final decision regarding the deposition of Mary Jane Veloso. The Court denied the motion, affirming the importance of concluding litigation and respecting the finality of judicial decisions.

Mary Jane’s Testimony: Can a Final Court Order Be Amended to Reflect Indonesia’s Conditions?

The case revolves around Mary Jane Veloso, a Filipina national convicted of drug trafficking in Indonesia. She was allegedly trafficked by Maria Cristina Sergio and Julius Lacanilao, who were subsequently charged in the Philippines with Qualified Trafficking in Persons, Illegal Recruitment, and Estafa. Mary Jane’s testimony was deemed crucial to the Philippine case, leading to a request for her deposition. The legal complexities arose when the Indonesian government imposed specific conditions for the deposition, which conflicted with the Philippine court’s initial orders. This prompted the Philippine prosecution to seek amendments to the Supreme Court’s final decision, resulting in the present legal challenge.

The core issue before the Supreme Court was whether a final and executory judgment could be modified to accommodate new conditions imposed by the Indonesian government regarding Mary Jane Veloso’s deposition. The Office of the Solicitor General (OSG) filed an Urgent Omnibus Motion, seeking to supplement the Court’s earlier decision with specific instructions aligning with Indonesia’s requirements. These requirements included that the deposition be conducted by the Indonesian Attorney General within the prison facility where Mary Jane is detained. The OSG argued that these new conditions necessitated a modification of the Court’s previous ruling, which had specified that the deposition be taken before the Philippine Consular Office in Indonesia.

However, the Supreme Court firmly rejected this motion, citing the well-established principle of finality of judgments. This principle dictates that once a judgment becomes final and executory, it is immutable, unalterable, and irreversible, even if it contains errors. The Court emphasized that this doctrine is essential for the orderly administration of justice, ensuring that litigation eventually comes to an end. As the Supreme Court stated,

“The orderly administration of justice requires that, at the risk of occasional errors, [judgments or resolutions] of a court must reach a point of finality set by the law. The noble purpose is to write finis to [a] dispute once and for all. This is a fundamental principle in our justice system, without which there would be no end to litigations.”

The Court acknowledged the established exceptions to this rule, which include: (a) correction of clerical errors; (b) judgments nunc pro tunc; and (c) void judgments. However, the OSG’s motion did not fall under any of these exceptions. The requested modification was not a mere correction of a clerical error but a substantive amendment to the Court’s decision. There was no basis to declare the original decision void, nor was there any inadvertent omission that could be rectified through a judgment nunc pro tunc. A judgment nunc pro tunc is defined as an action by the court to record some act done at a former time which was not then carried into the record.

The Supreme Court further elaborated on the nature of judgments nunc pro tunc, referencing the case of Briones-Vasquez v. Court of Appeals. As the Court explained,

“The office of a judgment nunc pro tunc is to record some act of the court done at a former time which was not then carried into the record, and the power of a court to make such entries is restricted to placing upon the record evidence of judicial action which has been actually taken. It may be used to make the record speak the truth, but not to make it speak what it did not speak but ought to have spoken.“

The Court emphasized that such judgments cannot be used to correct judicial errors or supply non-action by the court.

The Court also highlighted that the conditions set by the Indonesian authorities, as presented in the OSG’s motion, were not part of the information available to the Court when the original decision was rendered. The initial conditions known to the Court were limited to Mary Jane’s detention in Yogyakarta, restrictions on camera use, the absence of lawyers during the deposition, and the submission of written questions. The December 4, 2020 letter from the Indonesian government, containing the new and specific proposals, was only brought to the Court’s attention in the Urgent Omnibus Motion.

Given these considerations, the Supreme Court concluded that it could not alter a decision that had already become final and executory. The Court emphasized that Mary Jane is allowed to give her testimony through written interrogatories under the Rules of Court. The Court noted that the executive department, specifically the Department of Justice, had already played a crucial role in securing this legal avenue for Mary Jane. The Supreme Court clarified that the executive branch has the prerogative to handle foreign policy and negotiations, including accepting, rejecting, or modifying conditions set by Indonesia. In the Resolution, the Supreme Court stated:

“The Court finds this moment opportune to remark that the executive department need not obtain the assent of the judiciary in accepting, rejecting, or modifying the conditions set by Indonesia… It remains entirely within the prerogative of the executive department to handle matters and fill in the details of foreign policy and negotiations.”

Ultimately, the Supreme Court’s decision underscores the importance of adhering to established legal principles, even in complex and sensitive cases. The Court’s role is to interpret and apply the law, and once a decision becomes final, it must be respected. The resolution of any remaining issues lies within the purview of the executive branch, which is responsible for conducting foreign relations and negotiating with other countries. This separation of powers ensures that each branch of government fulfills its designated role in the pursuit of justice.

FAQs

What was the key issue in this case?	The key issue was whether the Supreme Court could modify a final and executory judgment to accommodate new conditions imposed by the Indonesian government regarding the deposition of Mary Jane Veloso.
What is the principle of finality of judgments?	The principle of finality of judgments states that once a judgment becomes final and executory, it is immutable, unalterable, and irreversible, even if it contains errors. This ensures that litigation eventually comes to an end.
What are the exceptions to the principle of finality of judgments?	The established exceptions include (a) correction of clerical errors, (b) judgments nunc pro tunc, and (c) void judgments. These exceptions are narrowly construed and did not apply in this case.
What is a judgment nunc pro tunc?	A judgment nunc pro tunc is an action by the court to record some act done at a former time which was not then carried into the record. It cannot be used to correct judicial errors or supply non-action by the court.
Why did the Supreme Court deny the OSG’s motion?	The Court denied the motion because it sought a substantive amendment to a final and executory judgment, which is not permissible under the principle of finality of judgments.
What role does the executive branch play in this case?	The executive branch, specifically the Department of Justice, is responsible for conducting foreign relations and negotiating with Indonesia regarding the conditions of Mary Jane Veloso’s deposition.
What were the initial conditions set for Mary Jane’s deposition?	The initial conditions were that Mary Jane remain in detention in Yogyakarta, no cameras be used, lawyers be absent, and questions be submitted in writing.
What new conditions were imposed by the Indonesian government?	The Indonesian government later specified that the deposition be conducted by the Indonesian Attorney General within the prison facility where Mary Jane is detained.

In conclusion, the Supreme Court’s resolution reinforces the importance of adhering to established legal principles and respecting the finality of judicial decisions. While the case involves sensitive international considerations, the Court’s role is to uphold the law. Any further negotiations or modifications must be handled by the executive branch.

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: PEOPLE OF THE PHILIPPINES VS. MARIA CRISTINA P. SERGIO AND JULIUS L. LACANILAO, G.R. No. 240053, March 21, 2022