G.R. No. 246553, December 02, 2020
Marilyn B. Montehermoso, et al., Petitioners, vs. Romeo Batuto and Arnel Batuto, Respondents.

FACTS

The case originated from a complaint for cancellation of title, reconveyance, and damages filed by respondents Romeo and Arnel Batuto. They claimed that a 44,410-square meter parcel of land was erroneously included in the petitioners’ OCT No. 5781. The Regional Trial Court (RTC) ruled in favor of the respondents in a Decision dated March 8, 2015, ordering the reconveyance of the property.
Petitioners subsequently initiated multiple legal actions to overturn this final RTC decision. They first appealed to the Court of Appeals, which dismissed their appeal in a Resolution dated August 5, 2016; this dismissal became final and executory on September 9, 2016, leading to the issuance of a writ of execution and demolition. Undeterred, petitioner Tanny Montehermoso alone filed a petition for relief from judgment, which the Court of Appeals also dismissed. Petitioners then elevated this denial to the Supreme Court via a petition for review on certiorari, which was denied. Subsequently, petitioners filed a petition for annulment of judgment before the Court of Appeals, alleging lack of jurisdiction by the trial court, which was likewise dismissed.

ISSUE

Whether the Court of Appeals correctly dismissed the petition for annulment of judgment, considering the doctrine of finality and immutability of judgments.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ resolutions. The Court emphasized the fundamental doctrine of finality or immutability of judgment, which holds that a decision that has attained finality becomes immutable and unalterable. It may no longer be modified, even to correct errors of fact or law, by any court. This principle ensures the orderly administration of justice and prevents endless litigation.
The Court found that the RTC Decision had long become final and executory as of September 9, 2016, and had already been implemented. For over five years, petitioners engaged in a barrage of successive and repetitive court actions—including an appeal, a petition for relief, a petition for review, and finally a petition for annulment—all attacking the same final judgment. This conduct constituted a clear violation of the immutability doctrine, trifled with the judicial process, and unjustly delayed the respondents’ rightful enjoyment of a final victory. The Court sternly warned both the petitioners and their counsel, Atty. Belinda M. Nagui, that any further attempt to revive the case would be severely sanctioned, reminding counsel of her superior duty as an officer of the court to uphold justice and resist clients’ propensity for frivolous litigation.