G.R. No. 42586 ; November 1, 1934
MARGARITA VILLARICA, petitioner, vs. PEDRO MA. SISON, ANTONIO HORRILLENO, and MANUEL V. MORAN, Judges of First Instance of Manila, ET AL., respondents.

FACTS

In Civil Case No. 44406, petitioner Margarita Villarica and defendant Andrea Cuison entered into a stipulation of facts, which the court approved in a Decision dated August 24, 1933. The stipulation included a confession of judgment by Cuison in favor of Villarica for a total of P6,300, with a clause stating “the judgment… will not be entered into until January 15, 1934.” The parties were notified of this Decision on August 26, 1933, and neither party moved for a new trial or appealed. On January 11, 1934, private respondents (the Tuasons, et al.) filed a motion to set aside the August 24, 1933 Decision and to intervene as third-party claimants. Respondent Judge Pedro Ma. Sison granted the motion on March 10, 1934, setting aside his prior Decision and allowing intervention. Villarica’s subsequent motions to set aside this order were denied by Judges Antonio Horrilleno and Manuel V. Moran. Villarica then filed this petition for certiorari, arguing the respondent judges acted without jurisdiction.

ISSUE

1. Whether the August 24, 1933 Decision was a valid judgment rendered upon a compromise.
2. Whether the respondent judge had jurisdiction to set aside his final Decision and to allow intervention after the judgment had become final.

RULING

The Supreme Court granted the petition.
1. The August 24, 1933 Decision was a valid judgment based on the parties’ compromise. Although the stipulation contained a defective clause about the judgment not being “entered into” until January 15, 1934, the parties’ conduct—by not objecting to the timeliness of the Decision upon notification—confirmed they considered it rendered. The court approved the stipulation and ordered compliance, making it a judicial decision.
2. The respondent judge acted without jurisdiction. The Decision became final after thirty days from notification (August 26, 1933) as no motion for new trial or appeal was filed. By March 10, 1934, the trial court had lost jurisdiction to alter, amend, or revoke the final judgment. Consequently, the order setting it aside and permitting intervention under Section 121 of Act No. 190 (the Code of Civil Procedure) was null and void, as intervention cannot be allowed after a judgment has become final. The subsequent orders denying Villarica’s motions were likewise void. The preliminary injunction was made permanent.

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