G.R. No. L-18397; November 29, 1962
GERONIMO T. SUVA, petitioner-appellant, vs. CECILIO CORPUS, ET AL., respondents-appellees.

FACTS

The Court of First Instance of Nueva Ecija ordered Geronimo Suva to pay damages to Cecilia Corpus, et al. This decision was affirmed by the Court of Appeals. Suva’s subsequent petition for certiorari to the Supreme Court was dismissed, rendering the judgment final and executory. The case was remanded for execution, and a writ was issued. Suva then filed a petition in the same trial court to enjoin the enforcement of the decision, alleging fraud, accident, mistake, excusable negligence, newly discovered evidence, and that the damages awarded were excessive or unjustified. He also sought a preliminary injunction.
Respondents moved to dismiss the petition, arguing lack of jurisdiction, failure to state a cause of action, and that it was barred by a prior judgment. The trial court, after a hearing on the preliminary injunction, denied the writ and granted the motion to dismiss. Suva appealed directly to the Supreme Court on pure questions of law.

ISSUE

Whether the trial court correctly dismissed Suva’s petition to enjoin the execution of a final and executory judgment.

RULING

Yes, the trial court’s dismissal was correct. The core legal principle is the immutability of final judgments. The decision Suva sought to nullify had already attained finality after the Supreme Court dismissed his petition for review. A final and executory judgment can no longer be altered, amended, or reopened, except for exceptionally narrow grounds not applicable here.
Suva’s petition, though framed as one to enjoin execution, was substantively a plea for a new trial based on the grounds listed in the rules. However, under the applicable Rules of Court (specifically those governing new trials and appeals), such a motion must be filed within a specific period—either before the judgment becomes final or within a reglementary period after its notice. Suva filed his petition long after finality had set in, placing it beyond the court’s authority to grant the relief sought. His claim of newly discovered evidence was also untenable, as the Court ruled the alleged evidence (that floodwaters, not his negligence, caused the damage) could have been discovered and presented during the original trial with due diligence. The trial court’s concise order, finding the petition not well-taken after considering the motion and opposition, constituted sufficient compliance. The ruling upholds the doctrine of finality of judgments, which is essential to the stability of judicial determinations.