Republic v. Heirs of Gotengco
REITERATIONFacts
1. The Antecedents: The Republic of the Philippines, through the Department of Public Works and Highways (DPWH), initiated an expropriation proceeding in 1977 to acquire properties owned by the Heirs of Cirilo Gotengco, Preciosa B. Garcia, and Emilia de Jesus for the construction of the Manila South Expressway Extension. The Regional Trial Court (RTC) of Calamba City, Branch 35, initially rendered a Partial Decision on January 31, 2000, fixing the just compensation for the expropriated lots. Following a motion for reconsideration by the Republic to correct the land area, the RTC issued a Modified Partial Decision on February 15, 2001, adjusting the just compensation amounts for Gotengco and de Jesus based on revised land areas. 2. Procedural History: After the Modified Partial Decision became final and executory, the RTC approved its execution on March 30, 2001. The Republic paid a portion of the just compensation to Gotengco, leaving a balance. Nine years later, on May 19, 2010, Gotengco filed an Omnibus Motion seeking payment of accrued interest on the just compensation from the date of finality of judgment until fully paid, and the surrender of a property title. The RTC granted this motion on July 20, 2010, ordering the payment of the balance with interest. Subsequently, Gotengco filed a Motion for Writ of Execution for the payment of interest, which the Republic opposed, arguing laches. On May 6, 2013, the RTC granted this motion, amending the Modified Partial Decision to include 6% per annum interest, reasoning that the interest was inadvertently excluded. The Republic's motion for reconsideration was denied. 3. The Petition: The Republic filed a petition for certiorari under Rule 45 of the Rules of Court with the Court of Appeals (CA), assailing the RTC's orders that amended a final and executory judgment. The Republic argued that the RTC committed grave abuse of discretion by violating the doctrine of immutability of judgments. The CA denied the petition, holding that the payment of interest is a matter of law and that the RTC did not commit grave abuse of discretion, citing jurisprudence that allows modification of judgments in exceptional circumstances to serve the ends of justice. The Republic then filed the present petition for review on certiorari with the Supreme Court, reiterating its argument that the CA erred in finding no grave abuse of discretion and that the RTC's orders violated the principle of immutability of judgments.
Issue(s)
Whether the trial court violated the doctrine of immutability of judgments by modifying its final and executory decision to include legal interest; and whether the Apo Fruits doctrine is applicable. Whether the Court of Appeals committed a reversible error in finding no grave abuse of discretion on the part of the trial court, considering the principles of estoppel by laches and res judicata as illustrated in Urtula v. Republic, and the overall violation of procedural rules.
Ruling
The petition is granted. The Decision of the Court of Appeals is reversed and set aside. The Modified Partial Decision of the Regional Trial Court, ordering the Republic to pay just compensation sans legal interest, is reinstated.
Ratio Decidendi
On the issue of immutability of judgments and the modification of a final and executory decision, and the applicability of the Apo Fruits doctrine: The Supreme Court reiterated the well-established rule that a judgment, once final and executory, cannot be altered, amended, or modified, even to correct an erroneous judgment. This is the principle of immutability of judgments, rooted in the legal maxim interest reipublicae ut sit finis litium. The Court found that the exceptions to this rule were not present in this case. The imposition of 6% legal interest was not a clerical error but a substantial change. There was no allegation of a void judgment, and no supervening events justified the modification. Therefore, the RTC's amendment violated the doctrine of immutability of judgments. The Court distinguished the present case from Apo Fruits. While Apo Fruits allowed relaxation of procedural rules, the present case lacked such compelling reasons. Gotengco filed his Omnibus Motion nine years after the Modified Partial Decision had become final and executory, which was clearly out of time and barred by laches. The Court emphasized that Apo Fruits is an exception, not the general rule, and it does not apply to those who sleep on their rights. On the issue of the Court of Appeals' finding of no grave abuse of discretion, considering estoppel by laches, res judicata as in Urtula v. Republic, and the overall violation of procedural rules: The Court found that Gotengco was guilty of laches because he waited nine years to assert his claim for legal interest. This unreasonable delay, coupled with the lack of knowledge on the part of the Republic and the potential prejudice to the Republic, led the Court to conclude that estoppel by laches had set in against Gotengco. The Court invoked the maxim vigilantibus non dormientibus equitas subvenit. The Court found the ruling in Urtula v. Republic to be more applicable. Similarly, Gotengco, by failing to raise the issue of legal interest in a timely manner, was barred by res judicata from claiming it in a belated motion. The Court concluded that affirming the CA's ruling would violate the doctrine of immutability and inalterability of a final judgment, leading to endless litigation and undermining the orderly administration of justice. Rules of procedure, while sometimes relaxed for compelling reasons, must generally be faithfully followed.
Main Doctrine
A judgment, once final and executory, cannot be altered or modified except under specific exceptions. The doctrine of immutability of judgments is upheld, and the relaxation of procedural rules, as in Apo Fruits, does not apply when the party seeking modification has been guilty of laches.