GR 185331; (June, 2016) (Digest)
G.R. No. 185331 . June 08, 2016
SPOUSES ABELARDO VALARAO AND FRANCISCA VALARAO, PETITIONERS, VS. MSC AND COMPANY, RESPONDENT.
FACTS
The case originated from a civil action for sum of money, damages, and rescission filed by MSC and Company (respondent) against Spouses Abelardo and Francisca Valarao (petitioners). The respondent, as contractor, entered into agreements with the petitioners to develop their land in Bulacan. The petitioners failed to fully pay stipulated mobilization expenses, pre-development costs, and progress billings, despite the respondent having completed 30% of the project. The Regional Trial Court (RTC) ruled in favor of the respondent, ordering the petitioners to pay a sum of money and decreeing the rescission of the agreements. The petitioners appealed to the Court of Appeals (CA).
The CA affirmed the RTC decision with modification on the reckoning of interest. Subsequently, the CA issued a Resolution declaring its Decision final and executory, noting no motion for reconsideration or Supreme Court petition was filed. The petitioners contested this, claiming they had filed a timely Motion for Reconsideration which remained unacted upon, leading them to file the present petition for review on certiorari.
ISSUE
The primary issue is whether the CA committed reversible error in declaring its Decision final and executory. A secondary issue pertains to the merits of the affirmed RTC decision.
RULING
The Supreme Court denied the petition. The legal logic centers on the doctrine of finality or immutability of judgment. The Court found the petitioners failed to sufficiently establish their claim of a timely filed Motion for Reconsideration. The copy attached to their petition was incomplete, lacking material portions like counsel’s signature. Crucially, records from the respondent showed the CA had already issued a Resolution dated November 19, 2008, which explicitly denied the petitioners’ Motion for Reconsideration. This resolution indicated the motion had been received and resolved, contradicting the petitioners’ assertion of inaction.
Since the CA Decision had become final and executory, the doctrine of immutability of judgment applies. This doctrine holds that a final judgment can no longer be altered, even to correct errors of fact or law, barring recognized exceptions such as correction of clerical errors, nunc pro tunc entries, void judgments, or supervening events making execution unjust. The Court found none of these exceptions present. Consequently, the petitioners’ remedy of a petition for review was no longer available after the judgment attained finality. Given this disposition on the threshold issue of finality, the Court deemed it unnecessary to address the secondary issue regarding the factual merits of the case.