G.R. No. 187425, July 18, 2012
COMMISSIONER OF CUSTOMS, PETITIONER, VS. AGFHA INCORPORATED, RESPONDENT.

FACTS

The case originated from the seizure of a shipment by the Bureau of Customs from respondent AGFHA Incorporated in February 1993. The Court of Tax Appeals Second Division (CTA-2D), in a Resolution dated October 18, 2005, adjudged the Commissioner of Customs liable to pay AGFHA the value of the lost shipment amounting to US$160,348.08, payable in Philippine currency at the prevailing exchange rate at the time of actual payment. The CTA-2D also imposed legal interest: 6% per annum from February 1993 until the finality of its resolution, and thereafter 12% per annum until full payment. The CTA En Banc affirmed this ruling in toto on February 25, 2009.
Subsequently, the Supreme Court, in a Decision dated March 28, 2011, affirmed the CTA En Banc’s decision. However, the dispositive portion of the Supreme Court’s Decision omitted any mention of the interest award, ordering only the payment of the principal amount. AGFHA filed a Motion for Clarification/Correction, contending the omission was inadvertent, as the body of the Decision contained no discussion to delete the interest. The Commissioner of Customs, in his Comment, did not oppose the inclusion of interest but argued that its computation should start only from August 13, 2004 (the date of formal judicial demand), not from February 1993.

ISSUE

Whether the Supreme Court’s March 28, 2011 Decision should be clarified to include the award of legal interest on the principal obligation, and if so, from what date should such interest be computed.

RULING

The Supreme Court granted the Motion for Clarification. The Court ruled that the omission of the interest award in its dispositive portion was indeed inadvertent. The legal logic is anchored on the doctrine of finality and immutability of judgment. The Court’s March 28, 2011 Decision expressly affirmed the February 25, 2009 Decision of the CTA En Banc, which in turn affirmed in toto the October 18, 2005 CTA-2D Resolution. Since the Supreme Court’s affirmation was unqualified and its decision contained no rationale modifying or deleting the interest component, the logical and necessary conclusion is that the interest award as originally decreed by the CTA-2D was sustained. A final and executory judgment, such as the CTA-2D Resolution which has been affirmed with finality, becomes immutable and unalterable. Neither the rendering court nor the Supreme Court can modify it in any respect, except for clerical errors or the execution of its terms.
Consequently, the Court clarified that its Decision includes the payment of interest as stipulated in the CTA-2D Resolution: legal interest at 6% per annum from February 1993 until the finality of that resolution, and 12% per annum thereafter until full payment. The Commissioner’s alternative computation starting from 2004 is barred by this principle of immutability; the final judgment has conclusively determined the reckoning date for interest.