G.R. No. 120739; July 20, 2000
PHILIPPINE COMMERCIAL AND INDUSTRIAL BANK (PCIBank), petitioner, vs. COURT OF APPEALS, SPOUSES SEGUNDO MARAVILLA and FEBE MARAVILLA, respondents.

FACTS

The spouses Maravilla secured a final and executory judgment against PCIBank for damages. A dispute arose regarding the applicable interest rate. The Court of Appeals, in CA-G.R. CV No. 32983, resolved this by ordering PCIBank to pay 12% interest on the principal actual damages and a 12% legal interest on the awarded damages, pursuant to Article 2212 of the Civil Code. This 1992 decision became final. Subsequently, PCIBank filed a “Motion for Clarification and/or Recomputation” with the trial court, contesting the computation of the interest. The trial court issued an order on June 2, 1993, computing PCIBank’s liability. The Maravillas moved for reconsideration, but the trial court denied it on July 19, 1993, declaring its June 2 order final for failure of the motion to contain a notice of hearing. The spouses then filed a certiorari petition with the Court of Appeals.

ISSUE

(1) Did the trial court commit grave abuse of discretion in denying the motion for reconsideration? (2) Did the Court of Appeals err in amending its final 1992 decision through its ruling in the certiorari petition?

RULING

First, the trial court did not commit grave abuse of discretion. A motion that does not contain a notice of hearing is a mere scrap of paper; the court acquires no jurisdiction to act on it and may simply deny it. The Maravillas’ proper remedy from the trial court’s June 2, 1993 order was a timely appeal, not certiorari, as the error was one of judgment, not jurisdiction. Second, and more critically, the Court of Appeals committed reversible error. Its 1992 decision in CA-G.R. CV No. 32983 had long become final and executory. A final judgment can no longer be amended, altered, or modified, even to correct a perceived error of law or fact. The exceptions are for clerical errors, nunc pro tunc entries, or void judgments, none of which apply here. By ruling in the certiorari case that the interest should be “compounded and capitalized periodically,” the appellate court substantively modified the fallo of its final 1992 decision, which had not provided for compounding. This was a clear overreach. The Supreme Court reinstated the 1992 decision in full.