Finality of judgment

A judgment can never be altered, amended or modified once it has attained finality even if the alteration, amendment or modification is to correct an error in said judgment. This is the principle of immutability of judgment to put an end to endless litigation as illustrated in this case involving James, an American citizen.

James was married to Tricia, a Filipina. The couple has a one-year-old son, Tom. After 13 years of marriage, James filed before the Regional Trial Court (RTC) a Petition for Declaration of Nullity of their Marriage because it was bigamous, since it turned out that he was still married to Eliza, an American citizen. The RTC granted the Petition and dissolved the marriage of James and Tricia after they agreed that the properties they acquired during their marriage shall go to Tricia and their son Tom.

Relying on this decision of the RTC, James cohabited with Linda, who gave birth to their child Chary. Then, nine years later, they decided to get married in order make their union legal and binding and to legitimize the status of Chary.

Four years later, James died. To settle his affairs, Linda requested from the RTC certified true copies of the decision dissolving the first marriage of James to Tricia, its certificate of finality and the entry of judgment, believing in good faith that it had attained finality after the lapse of 13 years from the date it was rendered. The branch clerk, however, discovered that the Republic, through the Office of the Solicitor General (OSG), was not furnished a copy of the decision. So instead of granting Linda’s request, the RTC furnished the OSG and gave it 15 days from receipt to perfect an appeal or file a motion for reconsideration. Thus the OSG sought reconsideration of the decision although it filed its motion more than 15 days thereafter.

The RTC ordered James to file a comment or opposition. This prompted Linda, though her counsel, to file a Manifestation and Special Appearance informing the RTC that James already died about a month ago; that 13 years before he died they already got married; that she has no knowledge about the issues of his past marital status because she could not locate James’ counsel of record.

The RTC granted the OSG’s motion and reversed its decision declaring the nullity of the marriage of James and Tricia, ruling that it is still valid and subsisting so the subsequent marriage of James to Linda is void. Thus Chary, the daughter of James and Linda, filed with the Court of Appeals (CA) a petition for annulment of said ruling of the RTC, alleging among others that her parents were legally married and that the three of them lived as a family.

The CA, however, dismissed the petition of Chary. The CA said that although the order of the RTC granting the motion of the OSG was issued 14 years after the rendition of the RTC decision declaring the marriage of James and Tricia as null and void, the RTC retained jurisdiction because said decision had not yet attained finality due to the failure to furnish the OSG with a copy thereof. Was the CA correct?

The Supreme Court (SC) ruled that the CA is not correct. The CA overlooked the fact that the OSG’s motion for reconsideration was belatedly filed, considering that it was done beyond the 15-day period. Thus the decision of the RTC declaring the marriage of James and Tricia as null and void ab initio became final. In effect the RTC already lost its jurisdiction over the case and could no longer reverse said decision.

This is the principle of immutability of judgment. In the interest of society as a whole, litigation must come to an end except if there are: (1) correction of clerical errors; (2) the so called nunc pro tunc entries which cause no prejudice to any party; (3) void judgments and (4) whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable. None of these exceptions exists in this case.

Finality of judgment becomes a fact upon the lapse of the reglementary period of appeal if no appeal is perfected, or motion for reconsideration or new trial is filed. The trial court need not even pronounce its finality, as the same becomes final by operation of law. Thereafter, the court loses jurisdiction over the case and not even the appellate court would have the power to review it. So the decision of the CA is reversed and set aside and the decision declaring the marriage of James and Tricia null and void is reinstated (Thomas vs. Trono and Republic, G.R. 241032, March 15, 2021).

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