G.R. No. 174542, August 03, 2015
Karen Go, Petitioner, vs. Lamberto Echavez, Respondent.

FACTS

Petitioner Karen Go, doing business as Kargo Enterprises, entered into a Contract of Lease with Option to Purchase a truck with Nick Carandang, her branch manager. Carandang failed to pay the installments and, instead of returning the truck, sold it to respondent Lamberto Echavez without Go’s knowledge. Go filed a Complaint for Replevin against Carandang and John Doe. The sheriff seized the truck from Echavez. Echavez filed an Answer with Counterclaim, alleging he bought the truck in good faith and for value, and sought actual damages of ₱10,000.00 per week for unrealized income from his business. The Regional Trial Court (RTC) rendered a Judgment dismissing the complaint against Echavez and ordering Go and Carandang to jointly and severally pay Echavez actual damages of ₱10,000.00 per week from the date of seizure, moral damages, exemplary damages, litigation expenses, and attorney’s fees. Go’s motion for reconsideration was partially granted, with the RTC maintaining Echavez’s entitlement to his counterclaim but also ordering Carandang to pay Go damages. Go appealed to the Court of Appeals (CA), but her appeal was dismissed for failure to file the required brief. Echavez moved for execution. Go filed a Motion for Clarification, arguing the award was inequitable and the judgment contained conflicting rulings because it upheld the lease contract’s non-assignment clause while also dismissing the complaint against Echavez. The RTC denied the motion and issued a Writ of Execution. The CA dismissed Go’s Petition for Certiorari, ruling the RTC committed no grave abuse of discretion. The CA noted the award was exorbitant but had become final.

ISSUE

1. Whether the February 11, 2000 RTC Judgment, as modified by the April 17, 2000 Order, contains materially conflicting rulings.
2. Whether the actual damages awarded to Echavez can still be modified.

RULING

The Supreme Court denied the petition for lack of merit.
1. The Judgment does not contain materially conflicting rulings. The RTC’s recognition of Carandang’s liability to Go for breach of the lease contract did not invalidate the sale to Echavez, who was found to be a buyer in good faith and for value. The lease contract bound only Go and Carandang. Echavez’s counterclaim was a separate action where he was the plaintiff and Go the defendant. The RTC could validly rule on the complaint and counterclaim separately, dismissing the complaint against Echavez while upholding his counterclaim against Go.
2. The actual damages awarded can no longer be modified. The RTC’s Judgment had become final and executory after Go’s appeal was dismissed. A final and executory judgment can no longer be altered, except for clerical errors or nunc pro tunc entries. The Court found no compelling reason to deviate from this doctrine. While the CA opined the award was exorbitant, it correctly recognized it could no longer modify the final judgment. The Court emphasized that a petition for certiorari under Rule 65 cannot be used to substitute for a lost appeal or to correct errors of judgment.