G.R. No. 208005 , November 21, 2018
RE: ADOPTION OF KAREN HERICO LICERIO. JOEL H. BORROMEO AND CARMEN H. BORROMEO, PETITIONERS.

FACTS

Petitioners Joel and Carmen Borromeo successfully filed a Petition for Adoption before the Regional Trial Court (RTC) of Marikina City to jointly adopt Karen Herico Licerio, Carmen’s illegitimate daughter. The RTC granted the petition in a Decision dated June 27, 2006, which ordered the City Civil Registrar (CCR) of Quezon City to annotate the decree of adoption on Karen’s birth record and issue a new certificate of birth. When petitioners sought to implement this decision, they discovered Karen’s birth was registered in both the CCR of Quezon City and the CCR of Caloocan City. The CCR of Quezon City advised that the registration in Caloocan must first be cancelled.
Consequently, petitioners filed a separate Petition for Cancellation in the RTC of Caloocan City, which instead merely ordered the correction of certain entries on Karen’s Caloocan birth certificate and did not cancel it. To execute the original adoption decree, petitioners then filed a Motion to Correct the Marikina RTC’s 2006 Decision, requesting that “City Civil Registrar of Caloocan City” be inserted in lieu of “City Civil Registrar of Quezon City.” The Marikina RTC denied this motion, invoking the doctrine of immutability of final judgments, ruling its decision had long become final and unalterable.

ISSUE

Whether the RTC of Marikina City erred in denying the Motion to Correct its final adoption decree based on the doctrine of immutability of judgment.

RULING

The Supreme Court granted the petition, ruling that the RTC of Marikina erred. The doctrine of immutability of judgment is not absolute and admits exceptions to serve substantial justice. The Court found that compelling circumstances justified a relaxation of the rule. Requiring the petitioners to file an entirely new action to resolve the mere ministerial act of identifying the correct civil registry office to implement the already-finalized adoption would be unnecessarily burdensome and would elevate procedural technicality over substantive rights.
The legal logic is that rules of procedure are tools to promote, not frustrate, justice. Their rigid application can be suspended when there exist: (a) matters of life, liberty, honor, or property; (b) compelling circumstances; (c) merit in the case; (d) a cause not solely attributable to the party’s fault; (e) a non-frivolous review; and (f) no unjust prejudice to the other party. These conditions were present. The Court held that the RTC of Marikina should not have outright denied the motion but should have received evidence on the duplicitous registration to determine the proper implementing office. The case was remanded to the RTC of Marikina to receive evidence, identify the correct civil registrar, and correct the decision only as to that ministerial detail, thereby harmonizing the final judgment with justice and the facts.