Mocorro v. Ramirez
REITERATIONFacts
The Antecedents: The underlying dispute concerns the operation of a cockpit in Caibiran, Leyte. The Philippine Gamefowl Commission (PGC) initially declared Dominador A. Mocorro, Jr. as the rightful operator, revoking the registration of Rodolfo Azur. Mocorro was issued a registration certificate and business permits to operate his cockpit, the Caibiran (Cockers) Gallera, for 1990 and 1991. However, respondent Rodito Ramirez, the municipal mayor, refused to issue Mocorro a business permit for 1992, despite Mocorro's application and payment of fees. Instead, permits were issued for cockfights in Edwin Rosario's name and subsequently in Azur's cockpit, commencing August 2, 1992. Procedural History: Mocorro filed a suit for injunction against Mayor Ramirez and Azur with the Regional Trial Court (RTC), docketed as Civil Case No. B-0837. The RTC issued a preliminary injunction, which was later made permanent, and found Ramirez and Azur guilty of indirect contempt for violating the injunction. The RTC ordered them to pay Mocorro actual damages of P2,000.00 every Sunday from August 2, 1992, attorney's fees, litigation expenses, and exemplary damages. The Court of Appeals (CA) affirmed the RTC decision. After the CA decision became final and executory, the RTC issued a writ of execution. The sheriff's computation of collectibles, including P2,000.00 for each Sunday from August 2, 1992, to June 22, 2001, amounted to P951,000.00, plus other costs, totaling P959,000.00. Ramirez and his wife filed a petition to exclude properties from execution, which the RTC denied. Ramirez then filed an Omnibus Motion to Quash Writ of Execution and Set Aside Sheriff's Computation, arguing the writ enforced an incomplete and void judgment. The RTC denied this motion. Ramirez then filed a petition for certiorari with the CA, seeking to nullify the RTC orders and the writ of execution. The CA partially granted the petition, setting aside the orders and writ concerning actual damages, finding the fallo of the RTC decision lacked an important data (the termination date for the P2,000 per Sunday liability) and that the RTC judge had substantially amended the final decision. The Petition: This petition for review on certiorari seeks to set aside the CA's decision, arguing that the CA erred in taking jurisdiction over the respondent's petition for certiorari and in eliminating the award of actual damages. The petitioner contends that the date when the respondent should stop paying the weekly actual damage is ascertainable from the decision itself and that the CA erred in holding the RTC decision void pro tanto and unexecutable with respect to actual damages. The petitioner argues that the respondent's actions, particularly filing a petition for certiorari to nullify a final and executory decision, constitute a ploy to modify a final judgment, which is impermissible. The petitioner asserts that the CA's ruling effectively allows the modification of a final and executory judgment, which is contrary to the principle of immutability of judgments, with the only exceptions being clerical errors, nunc pro tunc entries, or void judgments, none of which apply here.
Issue(s)
Whether the Court of Appeals erred in taking jurisdiction over the petition for certiorari and modifying a final judgment. Whether the Court of Appeals erred in eliminating the award of actual damages, considering the nunc pro tunc rule. Whether the Court of Appeals erred in holding that the RTC decision was defective and could not be executed with respect to actual damages, thereby undermining the principle of immutability of judgments.
Ruling
The Supreme Court granted the petition, modified the Court of Appeals' decision, and ordered the RTC to issue an amended decision. The Court ruled that the RTC decision, having become final and executory, was immutable and could not be modified. However, it applied the nunc pro tunc rule to clarify the computation of actual damages, holding respondent and Azur jointly and solidarily liable for P2,000 for every actual cockfight held from August 2, 1992, to June 22, 2001.
Ratio Decidendi
On the issue of the Court of Appeals' jurisdiction and the modification of a final judgment: The Supreme Court held that the petition for certiorari filed with the CA was a ploy to modify a final and executory judgment, which trifles with the administration of justice. A definitive final judgment, however erroneous, is no longer subject to change or revision due to the principle of immutability of judgments. This principle ensures that disputes reach a point of finality, preventing endless litigation. The Court emphasized that this immutability precludes modification even by the highest court, unless specific exceptions like clerical errors, nunc pro tunc entries, or void judgments apply. The CA's action in setting aside the award of actual damages based on a perceived defect in the fallo was deemed an impermissible modification of a final judgment. On the issue of actual damages and the nunc pro tunc rule: The Court acknowledged that the fallo of the RTC decision did not specify a terminal date for the P2,000 per Sunday award of actual damages, rendering the computation of the exact amount uncertain. However, instead of voiding the award, the Court invoked the exception for nunc pro tunc entries, which allows for the correction of omissions in the record to make the judgment speak the truth without supplying omitted action or correcting judicial errors. The Court reasoned that justice and equity dictated that respondent and Azur should be held solidarily liable for actual damages. The period for computation was clarified as from August 2, 1992, to June 22, 2001, the date the RTC decision became final and executory, ensuring that the judgment, while clarified, did not substantially alter the original disposition but merely supplied the missing detail for its execution. On the alleged voidness of the judgment and the principle of immutability: The Court found that the respondent's attempt to have the writ of execution quashed and the sheriff's computation set aside, by alleging the judgment was incomplete and void, was a stratagem to modify a final decision. The principle of immutability of judgments is a cornerstone of the justice system, and allowing such challenges would undermine the finality of court rulings. The RTC correctly denied the omnibus motion, stating that only the Supreme Court could nullify a CA decision, and that the respondent had failed to raise the alleged defects in the awards during the appeal process before the CA. Therefore, the CA erred in entertaining the certiorari petition on the grounds of an incomplete judgment regarding actual damages.
Main Doctrine
A final and executory judgment is immutable and unalterable, and cannot be modified even to correct errors of fact or law. Exceptions include clerical errors, nunc pro tunc entries, and void judgments. A nunc pro tunc entry corrects omissions in the record of actions actually taken, not judicial errors or omitted actions.