G.R. No. 95625 October 4, 1991
HIYAS SAVINGS AND LOAN BANK, petitioner, vs. COURT OF APPEALS, SPOUSES DELFIN MENDOZA AND SOLITA SANTOS AND SPOUSES FELIX SANTOS AND DEMETRIA PACHECO, respondents.

FACTS

Petitioner Hiyas Savings and Loan Bank was the defendant in a case for annulment of a mortgage contract. The trial court dismissed the complaint and rendered a final and executory judgment in favor of Hiyas, ordering the private respondents to pay, within 90 days, the principal loan of P200,000.00 with 14% annual interest from its maturity date, “ten percent (10%) of the amount due as and by way of attorney’s fees,” and costs. The judgment further stated that in default of payment, the mortgaged properties would be sold at public auction. Private respondents later deposited P428,600.00 in court as satisfaction of the judgment. Hiyas applied P40,735.35 of this amount as attorney’s fees.
Subsequently, Hiyas filed an amended motion for execution, claiming the total liability was P448,941.92, which included attorney’s fees computed at 10% of the sum of the principal and accrued interest. This left an alleged unsatisfied balance of P20,250.38. The trial court denied the motion, interpreting the phrase “amount due” in the attorney’s fees award to refer only to the principal loan of P200,000.00, thereby fixing the attorney’s fees at P20,000.00. The Court of Appeals upheld this denial, prompting Hiyas to elevate the case to the Supreme Court.

ISSUE

Whether the trial court, in interpreting the final and executory judgment, acted without jurisdiction by substantially amending it when it ruled that the awarded attorney’s fees constituted 10% of the principal amount only, and not 10% of the total amount due (principal plus interest).

RULING

The Supreme Court granted the petition and reversed the Court of Appeals. The Court held that the final and executory decision of the trial court unambiguously awarded attorney’s fees of ten percent (10%) of “the amount due.” There was no qualification in the dispositive portion limiting this to the principal sum. The ordinary and literal meaning of “amount due” in the context of a money judgment for a loan is the total outstanding obligation, encompassing both principal and accrued interest. This interpretation was consistent with the underlying loan documents.
The principle of immutability of final judgments prohibits a court from altering or amending a decision that has attained finality, except to correct clerical errors or mistakes. The trial court’s order, which effectively reduced the computed attorney’s fees by reinterpreting “amount due” to mean principal alone, was a substantive amendment that exceeded its jurisdiction. A court cannot, under the guise of clarification, change the clear import of a final judgment. The Supreme Court thus declared the total unsatisfied judgment debt to be P20,250.38 plus stipulated interest, and ordered the grant of the amended motion for execution.