G.R. No. 174698 ; July 28, 2008
Aurora Tamayo, Petitioner, vs. People of the Philippines and Heirs of Pedro Sotto, Respondents.

FACTS

Petitioner Aurora Tamayo and her co-accused, Erlinda Anicas, were charged with estafa under Article 315 of the Revised Penal Code. The Information alleged that they deceived spouses Pedro and Juanita Sotto by pretending to be assemblers of passenger jeepneys, convincing the spouses to order one unit for ₱120,000.00, and then misappropriating the money upon receipt. After trial, the Regional Trial Court (RTC) convicted Tamayo. The Court of Appeals affirmed the RTC decision in toto, and it became final and executory. A warrant for her arrest was subsequently issued.
Tamayo filed a motion to suspend the execution of the judgment, arguing that the penalty imposed by the RTC was incorrect. She contended that based on the amount involved (₱120,000.00), the penalty should have been arresto mayor in its maximum period to prision correccional in its minimum period, which is subject to the Indeterminate Sentence Law. The RTC denied her motion, ruling that the decision had attained finality and could no longer be modified. Tamayo elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Regional Trial Court committed a reversible error in denying petitioner’s motion to suspend execution on the ground that the penalty imposed in the final and executory decision was allegedly erroneous.

RULING

The Supreme Court denied the petition and affirmed the RTC order. The Court held that a final and executory judgment can no longer be altered, amended, or modified, even if the modification is meant to correct an erroneous application of the law. The doctrine of finality of judgment is a fundamental principle intended to end litigation. The RTC decision, as affirmed by the Court of Appeals, had long become final. Tamayo’s remedy was to appeal the judgment on time, not to file a motion to correct the penalty after finality.
The legal logic is clear: once a judgment becomes final, the court loses jurisdiction to amend it, save for clerical errors or the void judgment principle, which do not apply here. Tamayo’s claim of a misapplied penalty constitutes a judicial error in the appreciation of the law, not a clerical error. Such substantive errors are extinguished by the judgment’s finality. The proper execution of the final decision must proceed. The Court emphasized that allowing such post-finality corrections would undermine judicial stability and the rule of law.