GR 40490; (October, 1977) (Digest)
G.R. No. L-40490 October 28, 1977
ALFREDO BALQUIDRA, petitioner, vs. COURT OF FIRST INSTANCE OF CAPIZ, BRANCH 11, THE INCUMBENT PROVINCIAL GOVERNOR OF CAPIZ, CORNELIO VILLAREAL, JR. and the PROVINCE OF CAPIZ, respondents.
FACTS
Alfredo Balquidra was appointed as a provincial watchman in 1961. He assumed his duties, took his oath, and was covered by the GSIS as a permanent employee. On August 31, 1962, his services were terminated without formal charges, allegedly for the convenience of the government. Balquidra filed a petition for mandamus to compel his reinstatement and payment of back salaries. The Court of First Instance of Capiz, in a decision dated February 1, 1974, ruled in his favor, declaring his dismissal illegal and ordering his reinstatement with back salaries to be paid by the Provincial Government of Capiz.
Subsequently, the respondents filed a motion for reconsideration. The trial court, through a Resolution dated July 15, 1974, amended its original decision. While it maintained the order for Balquidra’s reinstatement, it eliminated the award for back salaries. Balquidra challenged this amended resolution, arguing that the trial court had lost jurisdiction to substantially alter its final and executory judgment.
ISSUE
The primary issue is whether the Court of First Instance of Capiz retained jurisdiction to amend its original decision by eliminating the award of back salaries after said decision had become final and executory.
RULING
The Supreme Court ruled in favor of the petitioner, Alfredo Balquidra. It set aside the amended resolution and reinstated the original decision with the award of back salaries. The legal logic is anchored on the doctrine of finality of judgment. The original decision was rendered on February 1, 1974. No appeal was perfected by the respondents within the reglementary period. Consequently, the judgment became final and executory. A court loses jurisdiction over a case once its decision becomes final, except to order its execution. It can no longer amend or alter the substantive portions of that judgment.
The Court rejected the respondents’ argument that the period to appeal should be reckoned from the date of the amendment. It held that an amended decision is a distinct judgment that must be filed with the clerk of court to be considered rendered. The amendment here, which eliminated a substantial monetary award, was a substantive alteration made after finality, which the trial court had no authority to do. On the merits of the back salary award, the Supreme Court affirmed its grant, citing its ruling in Cristobal v. Melchor, and awarded Balquidra back salaries for five years at his last received rate without deduction. The Provincial Government, as the real party in interest, was held liable for the payment.