Borromeo v. Borromeo
REITERATIONFacts
The Antecedents: Joel H. Borromeo and Carmen H. Licerio, a married couple with two legitimate children, sought to jointly adopt Karen Herico Licerio, the illegitimate minor daughter of Carmen. The adoption was intended to make Karen their legitimate child and allow her to use the surname Borromeo. Procedural History: The petitioners initially filed a Petition for Adoption with the Regional Trial Court (RTC) of Marikina City, which granted the adoption on June 27, 2006. Upon attempting to implement this decision, they discovered Karen's birth was registered in both Quezon City and Caloocan City. Advised to cancel the Caloocan City registration, they filed a Petition for Cancellation with the RTC of Caloocan City. This court, on May 23, 2012, ordered corrections to Karen's birth certificate entries (name and parents' marital status) but did not cancel the certificate. The RTC of Marikina City subsequently denied the petitioners' Motion to Correct its original decision to include the Caloocan City Civil Registrar, citing the immutability of final judgments. A motion for reconsideration was also denied. The Petition: The petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court, arguing that adoption and correction of civil registry entries are special proceedings to which the rule on immutability of judgment does not strictly apply. They contended that final judgments may be modified when subsequent circumstances render their execution unjust or inequitable. The Supreme Court considered whether the RTC of Marikina City erred in dismissing the motion to correct based on the doctrine of immutability of judgment, particularly in light of the discovered duplicitous birth registration and the subsequent inability to fully implement the adoption decree.
Issue(s)
Whether the RTC of Marikina City erred in dismissing the petitioners' Motion to Correct the decision due to the doctrine of immutability of judgment. Whether the doctrine of immutability of judgment admits of exceptions that would allow modification of a final and executory decision.
Ruling
The petition is meritorious. The assailed Orders dated May 23, 2013 and July 1, 2013 issued by the RTC of Marikina City are annulled and set aside. The case is remanded to the RTC of Marikina City with directions to receive evidence relevant to the duplicitous registration of Karen's birth, determine the proper OCR to enforce the June 27, 2006 Decision, and correct the decision, if needed, only as to the proper OCR to enforce it.
Ratio Decidendi
On whether the RTC of Marikina City erred in dismissing the petitioners' Motion to Correct the decision due to the doctrine of immutability of judgment: The Supreme Court ruled that the RTC of Marikina City erred. While the doctrine of immutability of judgment generally holds that a final decision becomes unalterable, the Court recognized that exceptions exist. The Court found that the fourth exception, "Whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable," was present in this case. The discovery of the duplicitous registration of Karen's birth and the subsequent refusal of the RTC of Caloocan City to cancel the registration created a situation where the original decision could not be enforced as written, making its strict execution inequitable and impossible. The Court disagreed with the RTC of Marikina City's position that it could not rule on the issue because it was not previously presented, emphasizing that rules of procedure should serve substantial justice and not become technicalities that frustrate it. The Court cited Candelario, et al. v. Canizares, et al. and Barnes v. Judge Padilla to support the principle that courts may suspend execution, admit new evidence, and grant relief based on supervening events. On whether the doctrine of immutability of judgment admits of exceptions that would allow modification of a final and executory decision: The Supreme Court affirmed that the doctrine of immutability of judgment is not absolute and admits of exceptions. Citing Antonio Mendoza v. Fil-Homes Realty Development Corporation, the Court reiterated the four exceptions: (1) correction of clerical errors, (2) nunc pro tunc entries, (3) void judgments, and (4) circumstances arising after finality that render execution unjust and inequitable. In this case, the fourth exception was deemed applicable due to the supervening event of the duplicitous birth registration and the subsequent inability to fully implement the adoption decree as originally ordered. The Court held that to strictly adhere to the immutability rule without considering these new circumstances would lead to a miscarriage of justice. The Court clarified that while the RTC of Marikina City could not outright change the dispositive portion to insert a new OCR, it was empowered to receive evidence and make necessary corrections to harmonize the decision with the factual developments and ensure its proper execution.
Main Doctrine
The doctrine of immutability of judgment admits of exceptions, particularly when circumstances transpire after the finality of a decision that render its execution unjust and inequitable, allowing for modification to harmonize the judgment with justice and the facts.