GR L 52118; (December, 1982) (Digest)
G.R. No. L-52118 December 15, 1982
Perfecto Fabular, petitioner, vs. Honorable Court of Appeals and Vicente Flandez, respondents.
FACTS
Petitioner Perfecto Fabular filed an application for registration of title over a parcel of land in Leyte. Private respondent Vicente Flandez opposed the application. After trial, the Court of First Instance rendered a decision on March 17, 1971, confirming Fabular’s ownership. The dispositive portion ordered Fabular to pay Flandez P10.00 as compensation for two non-fruit bearing coconut trees planted by Flandez’s father. This decision became final and executory.
Upon Fabular’s motion, the trial court issued a writ of execution on July 17, 1975, and Fabular paid the P10.00. However, more than four years after the decision and two months after the writ’s issuance, Flandez filed a motion for reconsideration. The lower court, in an order dated October 10, 1975, modified the writ, stating Flandez owned eight coconut trees and ordering Fabular to pay P20.00 per tree. Fabular’s motion for reconsideration was denied, prompting him to file a petition for certiorari with the Court of Appeals, which dismissed the petition.
ISSUE
Whether the Court of Appeals erred in sustaining the trial court’s order modifying the writ of execution after the judgment had become final and had been executed.
RULING
The Supreme Court ruled in the affirmative, reversing the Court of Appeals. The core legal principle is that once a judgment becomes final and executory, it is beyond the power of the court to amend or alter it, except for clerical errors. The only function left is the ministerial act of execution. This doctrine ensures the finality of judicial decisions, which is essential to the rule of law and the termination of litigation.
The Court held that the trial court’s modification was a substantive alteration, not a mere clarification conforming to the decision’s body. The dispositive portion of the March 17, 1971 decision explicitly ordered compensation for only two trees. What is controlling for execution is the decree in the dispositive part, not the reasoning in the body of the decision. Therefore, the trial court acted without jurisdiction when it issued the October 10, 1975 order, effectively changing the final judgment’s specific mandate. The subsequent orders based on this void act were likewise null and void.