Doctrine of immutability of judgment

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The doctrine of immutability of judgment bars the court from modifying decisions that have already attained finality even if the purpose of the modification is to correct errors of fact or law (Gadrinab vs. Salamanca, et al., GR 194560, June 11, 2014, Ponente: Associate Justice Marvic M. V. F. Leonen).
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However, there are instances where the court may relax its rules and this is in consonance with Section 6, Rule 1 of the 1997 Revised Rules of Court, as amended, which states that "these rules shall be liberally construed in order to promote their objective of securing a just, speedy and inexpensive disposition of every action and proceeding."

The Supreme Court enumerated instances for the relaxation of the principle of immutability of judgment and this finds support in the case of Latogan vs. People of the Philippines (GR 238298, Jan. 22, 2020) where the Supreme Court, speaking through Associate Justice Henri Jean Paul Inting, stated:

"Withal, as in the liberal construction of the rules on notice of hearing, the Court has enumerated the factors that justify the relaxation of the rule on immutability of final judgments to serve the ends of justice including: (a) matters of life, liberty, honor or property; (b) the existence of special or compelling circumstances; (c) the merits of the case; (d) a cause not entirely attributable to the fault or negligence of the party favored by the suspension of the rules; (e) a lack of any showing that the review sought is merely frivolous and dilatory; and (f) the other party will not be unjustly prejudiced thereby.

"In one case, the CA dismissed petitioner's appeal for failure to timely file a motion for reconsideration of the RTC's decision. According to the CA, the RTC decision could no longer be assailed pursuant to the doctrine of finality and immutability of judgments. Upon petition for review, though; the Court relaxed the application of the doctrine and held that the doctrine must yield to practicality, logic, fairness and substantial justice."

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Source:

https://www.manilatimes.net/2021/08/16/legal-advice/immutability-of-judgment/1811087