Philippine Health Insurance Corp. v. Chinese General Hospital
REITERATIONFacts
The Antecedents: Respondent Chinese General Hospital and Medical Center (CGHMC) had submitted claims to the Philippine Medical Care Commission (Medicare) for services rendered from 1989 to 1992, totaling P8,102,782.10. Following the enactment of Republic Act No. 7875 and the transfer of pending claims to the Philippine Health Insurance Corporation (Philhealth), Philhealth paid only P1,365,556.32 of CGHMC's claim. Subsequently, CGHMC filed claims for services rendered from 1998 to 1999, amounting to P7,554,342.93, which Philhealth denied on January 14, 2000, citing a violation of the sixty-day filing period. Procedural History: CGHMC appealed Philhealth's denial to the Court of Appeals (CA), which, on March 29, 2004, granted the petition and ordered Philhealth to pay P14,291,568.71 for both the 1989-1992 and 1998-1999 claims. This Court affirmed the CA's decision in G.R. No. 163123 on April 15, 2005, denying Philhealth's motion for reconsideration. CGHMC then filed a Motion for Execution with the CA, which was granted on July 12, 2006. The CA later modified this resolution on October 13, 2006, to explicitly include the 1998-1999 claims without conditions, and denied Philhealth's subsequent motion for reconsideration on November 27, 2006. The Petition: Petitioner Philhealth filed a Petition for Certiorari with this Court, assailing the CA's October 13, 2006 and November 26, 2006 Resolutions. Philhealth argued that the CA committed a legal error and grave abuse of discretion by ordering payment for the 1998-1999 claims, contending that this modified a final and executory judgment of this Court, which had only explicitly ordered payment for the 1989-1992 claims in its dispositive portion. Philhealth asserted that a final judgment cannot be amended or corrected.
Issue(s)
Whether the Court of Appeals committed legal error and grave abuse of discretion in modifying a final and executory judgment by ordering the payment of claims for the 1998-1999 period. Whether the Court of Appeals committed legal error and grave abuse of discretion in modifying a final and executory judgment by removing the condition of submitting pertinent documents; and whether the Supreme Court's Decision in G.R. No. 163123, which affirmed the Court of Appeals' decision, implicitly included the payment of claims for the 1998-1999 period despite the omission in its dispositive portion.
Ruling
The petition is DISMISSED. The assailed Resolutions of the Court of Appeals in CA-G.R. SP. No. 59294 are AFFIRMED.
Ratio Decidendi
On the alleged modification of a final and executory judgment regarding the 1998-1999 period: The Court held that the omission of the 1998-1999 claims in the dispositive portion of the Supreme Court's Decision in G.R. No. 163123 was a typographical error. This conclusion was supported by the fact that the Court of Appeals' decision, which was affirmed by the Supreme Court, clearly stated Philhealth's liability for claims covering both the 1989-1992 and 1998-1999 periods, amounting to P14,291,568.71. The Court reiterated the established doctrine that when a final and executory judgment contains a clerical error or ambiguity due to inadvertent omission, such error can be clarified by referring to the body of the decision itself. Citing Insular Life Assurance Company, Ltd. v. Toyota Bel Air and Locsin, et al. v. Paredes, the Court emphasized that the decision must be considered in its entirety to ascertain the true intent and meaning, and that ambiguities can be clarified even after a judgment has become final. On the alleged modification of a final and executory judgment regarding the condition of submitting pertinent documents, and the implicit inclusion of the 1998-1999 period in G.R. No. 163123: The Court found that the condition requiring CGHMC to submit pertinent documents for payment was not present in the Court of Appeals' decision or the Supreme Court's final and executory decision. If such a condition were intended, it would have been explicitly stated. Therefore, the deletion of this condition from the dispositive portion of the Court of Appeals' Resolution was not a grave abuse of discretion. The Court stressed that execution of a judgment is the ultimate goal of litigation, and delaying tactics by losing litigants frustrate the efforts of the courts. The Court expressed its desire to bring finality to the litigation, noting that the judgment had been final and executory since 2005 and still awaited full implementation due to delaying tactics.
Main Doctrine
A final and executory judgment with a clerical error or ambiguity in its dispositive portion may be clarified by reference to the body of the decision itself, without violating the doctrine of finality of judgment.