GR 167968; (January, 2006) (Digest)
G.R. No. 167968; January 23, 2006
VICENTE FLORENTINO, Petitioner, vs. MARIANO, CYNTHIA, ADELFA, all surnamed RIVERA and TEOFILA, MAXIMO, CIRIACO, NORBERTO, FELICIANO, JUAN GENEROSO, ANGEL, NOLASCO and MARCOSA, all surnamed MENDOZA, Respondents.
FACTS
The case originated from a complaint for rescission, annulment, and damages filed by the Riveras against Florentino. The Regional Trial Court (RTC) ruled in favor of the Riveras and the Mendozas, ordering Florentino to pay annual lease rentals and to compensate the Riveras for damages representing an “unrealized annual harvest of 100 cavans from 1978 up to the present.” This decision was affirmed by the Court of Appeals and subsequently became final and executory after the Supreme Court denied Florentino’s petition.
Upon the Riveras’ motion for execution, Florentino moved for reconsideration, arguing the dispositive portion was vague and contradictory to the appellate court’s finding in the body of its decision that the affected area could only yield 16.5 cavans annually. The RTC granted Florentino’s motion, issuing an order “clarifying” paragraph (cc) of its original decision by reducing the unrealized harvest from 100 to 16.5 cavans annually. The Riveras and Mendozas appealed this order.
ISSUE
Whether the trial court gravely abused its discretion in amending the dispositive portion of a final and executory judgment to substantially reduce the awarded damages.
RULING
Yes, the trial court committed grave abuse of discretion. The Supreme Court affirmed the Court of Appeals’ reversal of the RTC’s orders. The legal logic is anchored on the immutability of final judgments. A decision that has attained finality becomes immutable and unalterable; it may no longer be modified in any respect, even for perceived errors of law or fact. The power to clarify or correct a judgment is limited to clerical errors or ambiguities arising from oversight, not to substantial amendments that alter the rights of the parties.
Here, the RTC’s alteration was not a mere clarification but a substantive modification that changed the very quantum of damages from 100 to 16.5 cavans. This directly affected the vested rights of the prevailing parties under a final judgment. The perceived ambiguity between the dispositive portion and the body of the appellate decision did not justify such an amendment. The dispositive portion itself was clear and complete, stating a specific award. The doctrine of finality of judgment exists to end litigation, ensure judicial stability, and prevent endless suits. Allowing such post-finality modifications would undermine these principles and deprive the winning party of the fruits of a verdict. Thus, the trial court’s orders were correctly nullified for grave abuse of discretion.