Fabular v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Petitioner Perfecto Fabular sought to register title to a parcel of land measuring 1,016 square meters in Hilongos, Leyte. Private respondent Vicente Flandez opposed the application. The trial court initially ruled in favor of Fabular, ordering him to pay Flandez P10.00 for two non-fruit bearing coconut trees found on the property. 2. Procedural History: After the decision became final and was executed with the payment of P10.00, Flandez filed a motion to reconsider the decision. The trial court, on October 10, 1975, modified its earlier writ of execution, ordering Fabular to pay P20.00 for eight coconut trees. Fabular's motion for reconsideration of this modification was denied. Subsequently, Fabular filed a petition for certiorari and prohibition with the Court of Appeals, which dismissed his petition for lack of merit. 3. The Petition: This case is before the Supreme Court on a petition for review. The petitioner argues that the Court of Appeals erred in sustaining the trial court's order of October 10, 1975, which modified a final and executed judgment. The petitioner contends that once a judgment becomes final and has been executed, it can no longer be modified by the lower court, as doing so would allow for endless litigation.
Issue(s)
Whether the Court of Appeals committed an error in sustaining the trial court's modification of the writ of execution, considering the finality of the judgment. Whether a final and executory judgment can be modified by the lower court, and the principles governing the interpretation of the dispositive part versus the body of the decision.
Ruling
The Supreme Court reversed the judgment of the Court of Appeals and declared the lower court's orders dated October 10, 1975, and April 20, 1976, null and void. No costs.
Ratio Decidendi
On the issue of modifying a final and executory judgment: The Supreme Court held that modifying the writ of execution was an error because the judgment had long become final and executed. It is beyond the power of any court to modify a judgment that has attained finality. After a judgment becomes final, no additions can be made, and nothing can be done except its execution. To allow modifications would lead to endless litigation. In the present case, the dispositive portion of the trial court's decision explicitly ordered petitioner to compensate private respondent only the amount of P10.00 corresponding to two (2) non-fruit bearing coconut trees. Since the decision was already final and had been executed, the trial court acted without jurisdiction in modifying the writ of execution to include eight (8) coconut trees at P20.00 per tree. The modification constituted an alteration of the final judgment, which is impermissible. On the issue of modifying a final and executory judgment and the interpretation of the dispositive part versus the body of the decision: The Court disagreed with the Court of Appeals' ruling that the questioned order conformed with the substance of the decision and was not an amendment. It is a well-established principle that only the portion ordained or decreed in the dispositive part of a decision becomes the subject of execution. The body of the decision, while serving as a guide to the ratio decidendi, is not controlling. What is controlling is what appears in the dispositive part of the decision.
Main Doctrine
A final and executory judgment can no longer be modified by the lower court, as its power is limited to its execution. Any attempt to alter the dispositive portion of a final judgment constitutes an act without jurisdiction.