Immutability of Final Judgments

STRONGHOLD INSURANCE CO., INC., PETITIONER, VS. PAMANA ISLAND RESORT HOTEL AND MARINA CLUB, INC., RESPONDENT. G.R. No. 174838, June 01, 2016. 

“x x x.

Immutability of Final Judgments

The Court denies the petition. As correctly pointed out by the CA, the RTC’s order to implement carried substantial changes in a judgment that had become final and executory. These variations pertained to “(1) the date from which the double rate of interest on the principal amount of the claim, shall be computed; (2) up to when such interest shall run; and (3) the applicable rate of interest.”⁠2 Instead of “double the rate of interest [on the proceeds of insurance] from the date of demand until fully paid,”⁠3 the RTC’s computation for purposes of execution was limited to an interest rate of 6% per annum, resulting in a double rate of only 12% per annum, to be reckoned from the date of the trial court’s judgment until it became final and executory.

Clearly, the RTC’s issuances contravened a settled principle affecting execution of judgments. Time and again, courts have emphasized that a writ of execution must conform substantially to every essential particular of the judgment promulgated. An execution that is not in harmony with the judgment is bereft of validity. This applies because “once a judgment becomes final and executory, all that remains is the execution of the decision which is a matter of right. The prevailing party is entitled to a writ of execution, the issuance of which is the trial court’s ministerial duty.”⁠4 

While exceptions to the rule on immutability of final judgments are applied in some cases, these are limited to the following instances: (1) the correction of clerical errors; (2) the so-called nunc pro tunc entries which cause no prejudice to any party; and (3) void judgments⁠5 ] None of these exceptions attend Stronghold’s case.

Although some arguments advanced by Stronghold appeal to the substantive issues or merits of the RTC’s main judgment that favored Pamana, such matters have long been settled via the RTC decision that had become final and executory. Anent the computation of interest on Stronghold’s liability, it was explained that the notice of loss was promptly served upon Stronghold, but it took more than a year to reject the claim in violation of Section 243 of the Insurance Code.⁠6 Thus, double the applicable rate of interest on the principal award should be imposed.

X x x.”