G.R. No. L-20376-77 September 14, 1965
The People of the Philippines, plaintiff, vs. Dominador Vales y Victa, accused. T. V. Picache’s Agencia de Empenos, Inc., movant-appellant, H. E. Heacock, Inc., oppositor-appellee.

FACTS

On February 23, 1961, a criminal case for qualified theft was filed against Dominador Vales y Victa, an employee of H. E. Heacock, Inc., for stealing 311 pieces of assorted wrist watches. Another case for accessory after the fact was filed against Romeo Villadolid y Garcia on March 3, 1961, for pawning the stolen watches. On February 24, 1961, acting on a search warrant, the Manila Police Department seized 145 assorted wrist watches from T. V. Picache’s Agencia de Empenos, Inc. The two criminal cases were jointly tried. The accused initially pleaded not guilty but later substituted their plea to guilty of simple theft and accessory after the fact, but only for the value of P11,876.84. This amount was arrived at by deducting the value of 194 recovered watches, which included the 145 watches seized from Picache’s pawnshop. The court, in its decisions, directed that all stolen articles still in the custody of the Manila Police Department be returned to the complainant, H. E. Heacock, Inc. Pursuant to this, the police delivered the watches, including the 145 pieces from Picache, to Heacock. Seven months later, on September 3, 1962, Picache’s pawnshop filed motions in each case praying for the return of the 145 watches, claiming the court’s directive deprived it of property without due process. The court denied the motions on the ground that the decisions had already become final. Picache appealed.

ISSUE

Whether the trial court erred in denying the motions of T. V. Picache’s Agencia de Empenos, Inc. for the return of the 145 watches, which were seized from it but ordered delivered to H. E. Heacock, Inc. in the final criminal judgments.

RULING

The Supreme Court affirmed the trial court’s order denying the motions. The Court held that the motions were filed seven months after the decisions had been rendered and had become final and executory. At that point, the trial court had no more jurisdiction to alter, amend, or modify its decisions, except to correct clerical errors. The Court noted that while the trial court may have been mistaken in ordering the delivery of the watches to the offended party instead of directing that the claim be litigated in a separate appropriate action, this was merely an error of law that did not affect the court’s jurisdiction. The appellant’s cited case was distinguished because there the motion was filed within a reasonable time while the court still had jurisdiction. The appellant’s remedy was to assert its claim over the watches in a separate appropriate action against the proper party. The order was affirmed, with costs against the appellant.