Tuesday, September 1, 2015
Immutability of final judgments; exceptions.
PHILIPPINE WOMAN’S CHRISTIAN TEMPERANCE UNION, INC. VS. TEODORO R. YANGCO 2ND AND 3RD GENERATION HEIRS FOUNDATION, INC., G.R. No. 199595, April 02, 2014.
“x x x.
While firmly ingrained as a basic procedural tenet in Philippine jurisprudence, immutability of final judgments was never meant to be an inflexible tool to excuse and overlook prejudicial circumstances. The doctrine must yield to practicality, logic, fairness and substantial justice. Hence, it’s application admits the following exceptions: (1) the correction of clerical errors; (2) the so-called nunc pro tunc entries which cause no prejudice to any party; (3) void judgments; and (4) whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable.
Here, the third exception is attendant. The nullity of the RTC judgment and all subsequent rulings affirming the same, render inoperative the doctrine of immutability of judgment, and consequently justify the propriety of giving due course to the present petition.
To expound, the RTC judgment in LRC Case No. Q-18126(04) and all proceedings taken in relation thereto were void because the RTC did not acquire jurisdiction over the fundamental subject matter of TRY Foundation’s petition for the issuance of a title which was in reality, a complaint for revocation of donation, an ordinary civil action outside the ambit of Section 108 of P.D. No. 1529.
X x x.”