Philippine Veterans Bank v. Estrella
REITERATIONFacts
1. The Antecedents: Solid Homes, Inc. (SHI) filed a complaint against Philippine Veterans Bank (PVB) for specific performance, sum of money, and damages, alleging PVB reneged on a Compromise Agreement despite SHI remitting P28,937,965.65. SHI sought the release of condominium titles, a declaration of full compliance with the agreement, and damages including actual, goodwill, exemplary, and attorney's fees. PVB counterclaimed for rescission of the agreement and sought SHI's payment of damages. 2. Procedural History: The Regional Trial Court (RTC) of Pasig City granted SHI's motion for summary judgment and denied PVB's motion to dismiss. The original copy of the RTC's resolution stated an 18% interest rate on the P28,937,965.65, while copies served on the parties indicated 8%. PVB's motion for reconsideration was denied. Instead of appealing, PVB filed a petition for certiorari with the Supreme Court (SC) (G.R. No. 115847), alleging grave abuse of discretion regarding the 8% interest rate. The SC referred the petition to the Court of Appeals (CA), which dismissed it. The SC denied PVB's subsequent petition for review. Subsequently, SHI filed a Motion for Clarification with the RTC, asserting the 8% rate and alleging alteration of the original court copy. The RTC issued an order on May 6, 1999, clarifying the interest rate at 8% per annum. 3. The Petition: PVB filed a petition for certiorari under Rule 65 of the Rules of Court, seeking to nullify the RTC's May 6, 1999 order. PVB argued that the RTC judge committed grave abuse of discretion by fixing the interest rate at 8% when the original court document indicated 18%, which PVB claimed was consistent with the parties' Compromise Agreement. PVB contended that the assailed order was proof of bias and that the 8% rate was null and void. SHI countered that the petition was an attempt to resurrect a previously resolved issue and that the RTC order merely clarified an alteration in the original record, as the judgment had long become final and executory.
Issue(s)
Whether the RTC judge committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the May 6, 1999 Order clarifying the interest rate on the judgment debt, considering the finality of the original judgment. Whether the RTC had the jurisdiction to clarify its February 22, 1994 Resolution after it had become final and executory, and whether this clarification constituted an impermissible modification of a final judgment.
Ruling
The petition is dismissed for lack of merit. The assailed order of the RTC clarifying the interest rate at 8% per annum is affirmed.
Ratio Decidendi
On the issue of grave abuse of discretion and jurisdiction, and the finality of the judgment: The Supreme Court reiterated that once a final judgment becomes executory, it is immutable and unalterable, except for clerical errors or nunc pro tunc entries. The RTC's February 22, 1994 Resolution had long become final and executory. However, the RTC judge did not commit grave abuse of discretion in clarifying the interest rate because the assailed order was necessitated by an unauthorized alteration of the original record, where '1' was inserted before '8%' to make it appear as 18% instead of 8%. The RTC judge correctly determined that this alteration was not sanctioned by the court. PVB itself had acknowledged the 8% interest rate in its previous petition. Thus, the RTC's clarification was not a modification but a rectification of a falsified record. On the jurisdiction to clarify a final judgment and whether the clarification constituted an impermissible modification: The assailed Order dated May 6, 1999, did not amend or modify the Resolution of February 22, 1994. Instead, the order merely clarified the interest rate to rectify a falsification of the copy of the said resolution appended to the original records. In the exercise of its supervisory powers over the execution of a final and executory judgment, special circumstances attending its execution impelled the trial court to issue the assailed order clarifying the interest rate. The RTC's action was a proper exercise of its authority to ensure the correct execution of its judgment, especially when faced with evidence of tampering with court records.
Main Doctrine
A final and executory judgment is immutable and unalterable, except for the correction of clerical errors or the making of nunc pro tunc entries. A subsequent order clarifying the interest rate in a final judgment, necessitated by an unauthorized alteration of the original record, does not constitute a modification of the judgment.