G.R. No. L-51626. April 30, 1980.
EMMA TURQUEZA and LEO TURQUEZA, petitioners, vs. HON. HAROLD HERNANDO, Judge of the Court of First Instance of Abra, Branch I, and MARINA ELVENA-PACAPAC, respondents.

FACTS

Petitioners Emma and Leo Turqueza filed a damages suit against respondent Marina Elvena-Pacapac after Emma was severely injured in a vehicular accident involving a jeep owned by Pacapac. After Pacapac and her counsel failed to appear at the pre-trial despite notice, the respondent judge declared her in default. Petitioners were allowed to present evidence, leading to a judgment awarding them P56,000. No appeal was taken, making the judgment final and executory. The judgment was fully executed via a sheriff’s auction sale of Pacapac’s properties to the petitioners on September 1, 1978.
Subsequently, Pacapac filed a “Motion to Reopen Case,” invoking the court’s magnanimity, claiming the default judgment was due to her lawyer’s negligence. On November 6, 1978, respondent judge issued a “special order” allowing Pacapac to present her evidence while paradoxically stating the decision “shall remain undisturbed.” Petitioners’ motion for reconsideration was denied, prompting this certiorari petition to challenge the lower court’s jurisdiction to reopen a final and executed judgment.

ISSUE

Whether the respondent judge acted without jurisdiction or with grave abuse of discretion in issuing orders to reopen the case for reception of evidence after the judgment had become final and executory and had been fully satisfied.

RULING

Yes. The Supreme Court set aside the respondent judge’s orders as null and void. The Court emphasized the fundamental doctrine of finality of judgments. Once a decision becomes final and executory, it attains immutability and becomes the law of the case between the parties. The court that rendered it loses jurisdiction to alter, amend, or reopen it. This principle ensures judicial orderliness, economy of judicial time, and stability in legal relations. The respondent’s proper remedy from a judgment by default was a petition for relief under Rule 38, which must be filed within the reglementary period of sixty days from knowledge of the judgment and not more than six months from its entry. Pacapac’s motion, filed nearly a year after the judgment and after its execution, was filed out of time and could not legally be entertained. The respondent judge’s act of granting it, despite the lapse of jurisdiction, constituted grave abuse of discretion. The Court also admonished the judge for intemperate language used in his comment. The case was declared terminated, and the temporary restraining order was made permanent.