Aguila v. Baldovizo
REITERATIONFacts
1. The Antecedents: On April 19, 1993, a van registered to petitioner Danilo D. Reyes, driven by Marlun Lisbos, sideswiped Fausto T. Baldovizo while he was crossing EDSA in Caloocan City. Fausto sustained injuries and subsequently died on July 6, 1993. Subsequently, Fausto's widow and children filed a complaint for damages against the driver, Marlun Lisbos, the van's operator Emerlito F. Aguila, the registered owner Danilo D. Reyes, and the van's insurer, Times Surety and Insurance Company. 2. Procedural History: The Metropolitan Trial Court of Caloocan City charged Marlun Lisbos with reckless imprudence resulting in homicide. Separately, the Regional Trial Court (RTC) of Quezon City found petitioners Emerlito F. Aguila and Danilo D. Reyes jointly and severally liable for damages. The RTC's decision was affirmed by the Court of Appeals, which also denied petitioners' subsequent motions and petition for relief from judgment. The RTC later issued an Amended Decision on August 13, 2001, striking Marlun Lisbos's name from the dispositive portion, which the Court of Appeals also affirmed, ruling that the original decision had become final and executory and the Amended Decision was improper. 3. The Petition: Petitioners filed a petition for review on certiorari, arguing that they retained the right to appeal the Amended Decision, as it superseded the original decision and increased their liability due to the exclusion of Marlun Lisbos. They invoked substantial justice, praying to be absolved from liability. The Supreme Court, however, found the petition without merit, declaring the Amended Decision void for lack of jurisdiction and reinstating the original decision, noting that the petition for relief from judgment did not toll the reglementary period for appeal and that the principle of immutability of final judgments applied.
Issue(s)
Whether petitioners had the right to appeal the amended decision after the original decision had become final and executory. Whether the amended decision, which substantially altered the original decision by removing a party, is valid, and whether the original decision should be reinstated.
Ruling
The petition is denied for lack of merit. The Amended Decision dated August 13, 2001, of the Regional Trial Court of Quezon City, Branch 225, is declared void for lack of jurisdiction. The original Decision dated March 7, 2000, is hereby reinstated. The total amount adjudged therein shall earn an interest rate of 6% per annum from the date of judgment of the trial court until finality of this Decision. Thereafter, the total amount adjudged shall earn an interest rate of 12% per annum until it is fully paid.
Ratio Decidendi
On the right to appeal the amended decision: The Supreme Court held that petitioners did not have the right to appeal the amended decision because the original decision dated March 7, 2000, had already become final and executory. Petitioners received the original decision on April 24, 2000, and had until May 9, 2000, to file an appeal or a motion for new trial or reconsideration. Instead, they filed a petition for relief from judgment on May 4, 2000, which was not the proper remedy and did not toll the reglementary period. The Court emphasized that the Rules of Court are not mere tools to be discarded at will and that a litigant's resort to a wrong remedy cannot be rationalized by invoking liberal construction. On the validity of the amended decision and reinstatement of the original decision: The Court declared the Amended Decision dated August 13, 2001, void for lack of jurisdiction. It reiterated the principle of immutability of final judgments, stating that once a judgment becomes final and executory, the court loses its jurisdiction to amend, modify, or alter it, except for the correction of clerical errors or the making of nunc pro tunc entries that cause no prejudice. The amendment made by the RTC, which substantially affected the original judgment by removing a party, fell outside these exceptions. The Court noted that even if the driver (Lisbos) was included in the original decision, the employer (Aguila) and the registered owner/possessor (Reyes) are directly and primarily liable based on Article 2180 in relation to Articles 2184 and 2194 of the Civil Code in actions based on quasi-delict. Therefore, the amendment was unnecessary and void. The Supreme Court reinstated the original Decision dated March 7, 2000, finding it unnecessary to amend it. The Court clarified that the liability of petitioners Aguila and Reyes is solidary, as provided by Article 2194 of the Civil Code, regardless of the inclusion or exclusion of the driver in the judgment. The principle of immutability of judgments dictates that once a judgment becomes final, it can no longer be altered or modified, except for very limited exceptions not present in this case. The Court stressed that the RTC's act of amending a final and executory judgment was a grave abuse of discretion amounting to lack of jurisdiction.
Main Doctrine
An amended decision that substantially affects a final and executory judgment is void for lack of jurisdiction, as the court loses its power to amend or alter a judgment once it has become final, except for clerical errors or nunc pro tunc entries that cause no prejudice.