G.R. No. 240053 . March 21, 2022.
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. MARIA CRISTINA P. SERGIO AND JULIUS L. LACANILAO, RESPONDENTS.

FACTS

Mary Jane Veloso was arrested, convicted, and sentenced to death in Indonesia for drug trafficking. She had traveled to Indonesia based on respondents Maria Cristina Sergio and Julius Lacanilao’s false promise of work abroad. Respondents were charged in the Philippines with Qualified Trafficking in Persons, Illegal Recruitment, and Estafa. To secure Mary Jane’s testimony, Philippine prosecutors requested the Indonesian government to suspend her execution. Indonesia agreed but imposed conditions: Mary Jane must remain in Indonesia, and questions for her must be in writing. The prosecution sought to take her testimony via deposition upon written interrogatories. The Regional Trial Court (RTC) granted the request and outlined a procedure for the deposition, which would be presided over by the trial judge and conducted through the Philippine Consul in Indonesia. Respondents challenged the RTC’s order via certiorari before the Court of Appeals (CA), which reversed the RTC. The prosecution appealed to the Supreme Court. On October 9, 2019, the Supreme Court reversed the CA and reinstated the RTC’s resolution with modification, stating the deposition would be taken before Philippine consular officials in Indonesia. This Decision became final on March 4, 2020. Subsequently, the Office of the Solicitor General (OSG) filed an Urgent Omnibus Motion, seeking to supplement the October 9, 2019 Decision with specific instructions for the deposition’s conduct. This was due to a conflict between the court’s dispositions and new conditions set by Indonesia in a December 4, 2020 letter, which required that the deposition be conducted by the Indonesian Attorney General or appointees within the prison facility, with only a possible presence for the Philippine Consul and Presiding Judge.

ISSUE

Whether the Supreme Court should grant the OSG’s Urgent Omnibus Motion to supplement its final and executory October 9, 2019 Decision with specific guidelines for taking Mary Jane Veloso’s deposition, in light of new conditions imposed by the Indonesian government.

RULING

The Supreme Court resolved to note the Motion without action. The Court held that its October 9, 2019 Decision had already attained finality. As a rule, final and executory judgments are immutable and unalterable. The exceptions—correction of clerical errors, judgments nunc pro tunc, and void judgments—do not apply. The OSG’s request was not a mere correction but an amendment to the Decision. It did not seek to nullify a void judgment. Nor could it be treated as a judgment nunc pro tunc, as such entries only record previously rendered judicial actions, not render new judgments or correct judicial errors. The Court emphasized that the implementation details, including adapting to Indonesia’s conditions, fall within the prerogative of the executive department. The dispositive portion of the October 9, 2019 Decision used the word “will,” leaving the technicalities of execution to the Department of Justice and other agencies to negotiate with Indonesian authorities, considering the Decision’s spirit, applicable international treaties, Mary Jane’s circumstances, and the fact that the Philippines is the requesting state.