G.R. No. 168251; July 27, 2011
JESUS M. MONTEMAYOR, Petitioner, vs. VICENTE D. MILLORA, Respondent.

FACTS

On July 24, 1990, respondent Atty. Vicente D. Millora obtained a loan of ₱400,000.00 from petitioner Dr. Jesus M. Montemayor, evidenced by a promissory note. A loan contract executed on August 10, 1990, stipulated a 2% monthly interest and acknowledged an initial payment of ₱100,000.00 and ₱8,000.00 in interest. The interest rate was later increased to 3.5% per month with Millora’s consent. Millora failed to fully pay the interest from March to July 1991 and made no further payments despite demands. Consequently, Montemayor filed a Complaint for Sum of Money on August 17, 1993. In his Answer, Millora interposed a counterclaim for attorney’s fees of not less than ₱500,000.00, alleging he had rendered legal services to Montemayor for which he was summarily dismissed upon the filing of the complaint.
The Regional Trial Court (RTC) rendered a Decision on October 27, 1999, ordering Millora to pay Montemayor ₱300,000.00 plus 12% interest per annum from the filing of the complaint until fully paid. Simultaneously, the RTC found merit in Millora’s counterclaim and awarded him attorney’s fees on a quantum meruit basis, equivalent to the amount of his monetary liability to Montemayor, with the amounts to be set off against each other. The dispositive portion stated: “whatever amount recoverable from defendant shall be set off by an equivalent amount awarded by the court on the counterclaim representing attorney’s fees of defendant on the basis of ‘quantum meruit’ for legal services previously rendered to plaintiff.”
Millora filed a Motion for Reconsideration (denied on June 23, 2000) and a Motion for Issuance of a Writ of Execution regarding the attorney’s fees award (granted in the same June 23, 2000 Order). His subsequent Notice of Appeal was denied by the RTC on July 10, 2000, as the Decision had become final and executory on July 1, 2000. Montemayor filed a Motion for Reconsideration and Clarification of the June 23, 2000 Order, which was denied by the RTC on September 6, 2002, along with his own Motion for Issuance of a Writ of Execution. His Motion for Reconsideration of this denial was also denied on October 2, 2003.
Montemayor elevated the case to the Court of Appeals (CA) via a Petition for Certiorari. The CA denied the petition and affirmed the RTC Orders in its Decision dated May 19, 2005. Montemayor then filed the present Petition for Review on Certiorari.

ISSUE

Whether, despite the finality of the RTC Decision and the absence of a specific quantified amount for the attorney’s fees awarded under the counterclaim, such award can be validly offset against the specific monetary award in favor of the petitioner.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed CA Decision.
The Court held that the October 27, 1999 RTC Decision had long become final and executory, and thus immutable. A final judgment can no longer be modified, even to correct perceived errors, except for clerical errors, nunc pro tunc entries, or if the judgment is void. The doctrine of finality of judgment is grounded on public policy and sound practice.
On the substantive issue, the Court ruled that the amount of attorney’s fees awarded, though not specified as a numerical figure in the dispositive portion, was ascertainable from the text of the Decision itself. The RTC clearly ordered that the attorney’s fees be “equivalent to the amount of Vicente’s monetary liability.” Since Millora’s monetary liability was specifically adjudged as ₱300,000.00, the attorney’s fees award was correspondingly fixed at the same amount by operation of the judgment. Therefore, both obligations were liquidated and determinate, making legal compensation or offsetting proper under Article 1279 of the Civil Code. The Court emphasized that when the dispositive portion of a judgment is clear and unequivocal, it must be executed strictly according to its tenor. The RTC did not commit grave abuse of discretion in ordering the execution and offsetting as decreed in its final Decision.