GR 226355; (January, 2018) (Digest)
G.R. No. 226355, January 24, 2018
Republic of the Philippines, represented by the DPWH vs. Heirs of Cirilo Gotengco
FACTS
The Republic, through the DPWH, expropriated properties for the South Luzon Expressway in 1977. The RTC of Calamba City rendered a Modified Partial Decision on February 15, 2001, fixing just compensation for the landowners, including respondent Gotengco. This decision became final and executory. The Republic partially paid Gotengco but a balance remained. Nine years after the decision’s finality, Gotengco filed an Omnibus Motion in 2010, praying for payment of accrued interest on the just compensation from the date of finality of judgment. The RTC granted this motion in 2010, ordering interest payment. Gotengco later filed a Motion for Writ of Execution for the interest.
The Republic opposed, arguing Gotengco was barred by laches for not claiming interest earlier and that the final judgment could not be amended. The RTC, in 2013, granted the execution and effectively amended the final 2001 Modified Partial Decision to include interest, citing inadvertent omission and the interest of justice. The CA denied the Republic’s certiorari petition, upholding the RTC’s actions. The Republic elevated the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the RTC committed grave abuse of discretion in amending a final and executory judgment to award legal interest on the expropriation compensation.
RULING
Yes, the RTC committed grave abuse of discretion. A final and executory judgment is immutable and unalterable. Exceptions to this rule are limited, such as the correction of clerical errors or the so-called nunc pro tunc entries which cause no prejudice. The RTC’s amendment to incorporate an award of legal interest constituted a substantial alteration of the dispositive portion of the final judgment, which is prohibited. The Court emphasized that the power to amend judgments ends once finality sets in; otherwise, litigation would never cease.
The legal logic is grounded in the doctrine of immutability of final judgments, a cornerstone of judicial stability. The RTC’s justification—that the interest was inadvertently omitted—was insufficient, as the omission was not merely clerical but substantive. A clerical error refers to a mistake in transcription, not an omission in the court’s adjudication. The proper remedy for Gotengco, if he believed he was entitled to interest from the start, was to appeal the original 2001 decision, not to seek its amendment years after finality. Consequently, the Supreme Court reversed the CA decision and nullified the RTC orders amending the final judgment.