Briones-Vasquez v. Court of Appeals
REITERATIONFacts
The Antecedents: Under a pacto de retro sale, Maria Mendoza Vda. De Ocampo acquired a parcel of land from Luisa Briones, with the seller reserving the right to repurchase the property by December 31, 1970. After Maria Mendoza Vda. De Ocampo's death, her heirs, Hipolita Ocampo Paulite and Eusebio Mendoza Ocampo, filed a petition for consolidation of ownership, asserting that the seller failed to exercise her right of redemption within the stipulated period. Procedural History: The Regional Trial Court (RTC) of Pili, Camarines Sur, initially ruled that the transaction was a true pacto de retro sale and allowed the defendant (Luisa Briones) to redeem the property within 30 days from the finality of the judgment. The heirs appealed this decision to the Court of Appeals (CA), which reversed the RTC's ruling, declaring the sale with right of repurchase as an equitable mortgage. The CA denied a subsequent motion for reconsideration, and its decision became final and executory. Attempts to execute the CA's decision by the heirs proved unsuccessful, leading to the filing of an omnibus motion by Luisa Briones with the RTC, seeking to declare the equitable mortgage discharged and for a writ of possession. The RTC denied this motion, stating it could no longer alter the final and executory decision of the CA. The RTC also denied Briones' motion for reconsideration. Briones then filed a motion for clarificatory judgment with the CA, which was denied, as was her subsequent motion for reconsideration. The Petition: Petitioner Luisa Briones-Vasquez filed a petition for certiorari under Rule 65 of the Rules of Civil Procedure, assailing the CA's resolutions denying her motion for clarificatory judgment and her motion for reconsideration. She argued that the CA acted arbitrarily and with grave abuse of discretion. The core issue presented to the Supreme Court was whether the CA committed grave abuse of discretion in refusing to grant the motion for clarificatory judgment, particularly in light of the final and executory nature of the CA's decision which declared the transaction an equitable mortgage, not a sale.
Issue(s)
Whether the Court of Appeals acted with grave abuse of discretion amounting to lack of jurisdiction in denying petitioner’s motion for clarificatory judgment. Whether a motion for clarificatory judgment can be used to amend or clarify a final and executory decision of the Court of Appeals.
Ruling
The petition for certiorari is DISMISSED. The parties are directed to proceed upon the basis of the final Decision of the Court of Appeals, dated June 29, 1995, in CA-G.R. CV No. 39025, that the contract in question was an equitable mortgage and not a sale.
Ratio Decidendi
On the issue of whether the Court of Appeals acted with grave abuse of discretion amounting to lack of jurisdiction in denying petitioner’s motion for clarificatory judgment: The Supreme Court held that the Court of Appeals did not act arbitrarily or with grave abuse of discretion. This is because the CA's decision had already become final and executory when the motion for clarificatory judgment was filed. The Court reiterated the principle that final and executory judgments are immutable and unalterable, with very limited exceptions such as the correction of clerical errors or the making of nunc pro tunc entries that cause no prejudice. The petitioner's motion did not fall under these exceptions, as it sought to clarify or amend the judgment rather than merely record what was previously done but omitted from the record. Therefore, the CA correctly denied the motion. On the issue of whether a motion for clarificatory judgment can be used to amend or clarify a final and executory decision of the Court of Appeals: The Supreme Court clarified that the office of a judgment nunc pro tunc is to record acts already taken but omitted from the record, not to supply omitted action or correct judicial errors. A motion for clarificatory judgment, in the context of a final and executory decision, cannot be used to alter, modify, or add to the judgment. The Court emphasized that if the judgment is perceived as erroneous, it cannot be remedied through such a motion after it has become immutable. The petitioner's request for clarification was deemed an attempt to modify the final judgment, which is impermissible. The Court also noted that the CA's ruling that the contract was an equitable mortgage meant that the provisions governing mortgages, including the prohibition against pactum commissorium, would apply, and the proper remedy for the creditor would be foreclosure, not consolidation of ownership.
Main Doctrine
A motion for clarificatory judgment, seeking to amend or clarify a final and executory decision, cannot be granted if it seeks to correct judicial error or supply omitted action by the court, as such judgments are outside the scope of nunc pro tunc entries. The only recourse for a party seeking to enforce or clarify rights under a final judgment is through the proper remedies available for execution, not by altering the judgment itself.