GR 142669; (March, 2006) (Digest)
G.R. No. 142669 . March 15, 2006.
PHILIPPINE ECONOMIC ZONE AUTHORITY (PEZA), represented by its Baguio City Economic Zone Administrator, DIGNA TORRES, Petitioner, vs. ABRAHAM B. BORRETA, Presiding Judge, Regional Trial Court, Baguio City, Branch 59, and BENEDICTO CARANTES, Respondents.
FACTS
Private respondent Benedicto Carantes was convicted for constructing a house without a building permit within the Baguio City Economic Zone, an area under PEZA’s administration. The trial court’s 1994 Decision, which ordered him to pay a fine and to demolish the subject structures, was affirmed by the Court of Appeals and became final and executory in 1997. During execution, Carantes demolished one structure but sought to exclude another, claiming it was built earlier. The trial court denied his motion, ruling the final decision covered both structures. Later, Carantes filed a Manifestation stating the City Engineer of Baguio had issued a building permit for the remaining structure and presented a Certificate of Ancestral Land Claim.
ISSUE
Whether the trial court committed grave abuse of discretion in modifying a final and executory judgment based on a subsequently issued building permit and an ancestral land claim.
RULING
Yes. The Supreme Court granted the petition and nullified the trial court’s orders. The Court emphasized the doctrine of immutability of final judgments. A decision that has attained finality can no longer be altered, except to correct clerical errors or under specific, limited exceptions such as a change in the parties’ situation making execution unjust, or a showing that the judgment debt has been satisfied. None of these exceptions were present. The belatedly presented building permit from the City Engineer and the Certificate of Ancestral Land Claim constituted new matters that Carantes raised to obstruct execution, which is not permitted. Furthermore, the Court noted that under applicable laws, the authority to issue building permits within the economic zone is vested solely in PEZA, not the City Engineer. The trial court’s act of effectively amending a final judgment based on these new issues was a grave abuse of discretion. The Court ordered the full implementation of the writ of demolition for the remaining structure.