G.R. No. 197654 . August 30, 2017.
MERCURY DRUG CORPORATION AND ROLANDO J. DEL ROSARIO, PETITIONERS, VS. SPOUSES RICHARD Y. HUANG & CARMEN G. HUANG, AND STEPHEN G. HUANG, RESPONDENTS.

FACTS

On April 29, 1997, respondents Stephen Huang and his parents filed a complaint for damages based on quasi-delict against petitioners Mercury Drug Corporation and its driver, Rolando J. Del Rosario, arising from a vehicular accident on December 20, 1996, which rendered Stephen a paraplegic. The Regional Trial Court (RTC) rendered a Decision on September 29, 2004, holding petitioners jointly and severally liable to pay various damages, including P23,461,062.00 for life care cost and P10,000,000.00 for lost earning capacity. The Court of Appeals affirmed the RTC Decision but reduced moral damages. The Supreme Court, in Mercury Drug Corporation v. Spouses Huang, affirmed the Court of Appeals Decision in a Resolution dated June 22, 2007. A Motion for Reconsideration was denied with finality on August 8, 2007, and entry of judgment was made on October 3, 2007.
Upon respondents’ motion, the RTC issued a Writ of Execution on July 21, 2008. Petitioners filed a Motion to Quash the Writ, a Motion for Inhibition, and an Urgent Motion to Defer Implementation, all of which were denied. The sheriff garnished petitioners’ bank accounts, and a Manager’s Check for P40,434,062.00 was issued to respondents, who subsequently filed a Satisfaction of Judgment. Petitioners filed a Petition for Certiorari before the Court of Appeals, arguing that the RTC committed grave abuse of discretion in allowing execution despite alleged clerical errors in the computation of the life care cost and loss of earning capacity awards. The Court of Appeals denied the petition, upholding the doctrine on the immutability of final judgments. Petitioners’ motion for reconsideration was also denied.

ISSUE

Whether the Court of Appeals erred in sustaining the denial of petitioners’ Motion to Quash the Writ of Execution, thereby allowing the execution of a final and executory judgment that petitioners claim contains clerical errors in the computation of damages and should be paid in installments.

RULING

The Supreme Court denied the petition. The Court held that the judgment had long become final and executory, and the doctrine of immutability of judgments precludes any alteration or modification. The alleged errors in computation were not clerical but involved a reevaluation of the factual and legal bases of the awards, which would constitute a prohibited substantial amendment. The Court found that the body of the RTC Decision clearly discussed and justified the amounts awarded for life care cost and loss of earning capacity, and these specific amounts were unequivocally stated in the dispositive portion. Therefore, the Writ of Execution conformed to the judgment.
Furthermore, the Court ruled that the damages awarded were in the nature of a lump-sum compensation for injuries sustained and future pecuniary losses, not akin to support that could be paid periodically. The judgment did not provide for payment by installment, and under Rule 39, Section 9(a) of the Rules of Court, execution should issue for the full amount. Petitioners’ attempt to assail the execution was an indirect attack on the final judgment, which is not permitted. The principle of finality of judgment ensures the conclusiveness of litigation and must be upheld.