Aguila vs. Baldovizo

A judgment that has become final and executory can no longer be amended, modified, or altered by the trial court, except for correction of clerical errors, nunc pro tunc entries that cause no prejudice, or when the judgment is void. Any amendment or alteration that substantially affects a final and executory judgment is null and void for lack of jurisdiction, and the original judgment is reinstated.

Petitioners Emerlito F. Aguila and Danilo D. Reyes were respectively the actual operator and possessor, and the registered owner, of a van involved in a vehicular accident. Respondents Carmen R. Baldovizo and her children Edgar and Carmelo are the surviving spouse and heirs of Fausto T. Baldovizo, who died from injuries sustained in the accident. The case involves the application of the principle of immutability of final judgment in the context of a damages action based on quasi-delict, where the Civil Code provides for the solidary liability of employers and owners of motor vehicles.

On April 19, 1993, at about 11:30 a.m., Marlun Lisbos was driving a van with Plate No. TER-883 along Epifanio de los Santos Avenue (EDSA) in Caloocan City. The van was registered under the name of petitioner Danilo D. Reyes. The van sideswiped Fausto T. Baldovizo, who was walking along the pedestrian lane in front of the Monumento Market in Caloocan City while crossing EDSA. Fausto fell on the pavement and suffered injuries, and was brought to the Manila Central University Hospital for treatment. He subsequently died on July 6, 1993.

On May 20, 1994, Marlun Lisbos was charged with reckless imprudence resulting in homicide at the Metropolitan Trial Court of Caloocan City, Branch 52. On September 24, 1994, Fausto's wife, Carmen R. Baldovizo, and children, Edgar and Carmelo, filed a separate complaint for damages before the RTC of Quezon City, Branch 225, against Marlun Lisbos, Danilo D. Reyes, petitioner Emerlito F. Aguila (the actual operator and possessor of the van), and Times Surety and Insurance Company (the insurer of the van under a third-party liability insurance contract). Summons were served on all defendants except Marlun Lisbos, whose whereabouts were unknown according to the Sheriff's Report.

In his Answer, Aguila claimed that Fausto disregarded traffic rules when he crossed EDSA, that Aguila exercised due diligence in the selection of Lisbos as driver, and that Aguila provided assistance and support during Fausto's hospitalization. Reyes, for his part, denied ownership of the van, claiming that although the van was registered in his name, Aguila was its actual possessor and operator, and thus Reyes could not be liable for damages. Times Surety and Insurance Company was declared in default for failure to file an Answer.

After the parties failed to arrive at a settlement, trial ensued. Petitioners were considered to have waived their right to present their evidence due to their failure to appear on the December 1, 1999 hearing. On March 7, 2000, the trial court rendered a decision ordering the defendants to jointly and severally pay ₱43,800.00 for loss of earning capacity, ₱110,700.00 for medical expenses and hospital bills, ₱15,800.07 for medicine expenses incurred after confinement, ₱50,000.00 as death indemnity, ₱50,000.00 as moral damages, ₱20,000.00 as exemplary damages, and costs of suit.

On May 4, 2000, petitioners Aguila and Reyes filed a petition for relief from judgment before the RTC, which was denied in a Resolution dated November 20, 2000. The Baldovizos then moved for the issuance of a writ of execution after the judgment attained finality. Petitioners filed a motion for reconsideration of the November 20, 2000 Resolution and a motion to dismiss for lack of jurisdiction on the ground that the certification against forum shopping was defective. On May 21, 2001, the trial court granted the motion for the issuance of a writ of execution and denied petitioners' motions. On June 26, 2001, petitioners filed a motion for reconsideration of the order for the issuance of the writ of execution and informed the trial court of their intention to appeal the November 20, 2000 Resolution, simultaneously filing a second motion for reconsideration of that Resolution.

On August 13, 2001, the trial court denied the second motion for reconsideration and the reconsideration of the order for the issuance of the writ of execution. In addition, the trial court resolved to strike off the name of Marlun Lisbos in the dispositive portion of its March 7, 2000 Decision for having been inadvertently included therein, issuing an Amended Decision that deleted Lisbos's name as a party liable for damages. Petitioners appealed the Amended Decision before the Court of Appeals, which denied the appeal for being improper, ruling that Aguila and Reyes had lost their right to appeal since no appeal of the March 7, 2000 Decision was made within the reglementary period, and the Amended Decision did not give the parties a fresh period within which to file an appeal. The appellate court also held that petitioners' attempt to revive their rights failed after their petition for relief from judgment was denied for lack of merit.

• Right to Appeal the Amended Decision: Petitioners contended that while their right to appeal the March 7, 2000 Decision had been lost, their right to appeal the August 13, 2001 Amended Decision remained, claiming that the Amended Decision superseded the original decision because the amount of their liabilities increased as a result of the exclusion of Marlun Lisbos.
• Cognizance of Appeal: Petitioners added that the Court of Appeals should have taken cognizance of their appeal since their notice of appeal was approved by the trial court.
• Substantial Justice: Petitioners invoked substantial justice for the Court to consider the merits of the case which the appellate court failed to address, praying that they be absolved from liability.

N/A — The decision does not recount the respondents' specific arguments before the Supreme Court.

• Right to Appeal the Amended Decision: Whether the petitioners have the right to appeal the amended decision after the original decision had become final and executory.

• Right to Appeal the Amended Decision: No. The Amended Decision dated August 13, 2001 is null and void for lack of jurisdiction because any amendment or alteration made which substantially affects a final and executory judgment is null and void. The original Decision dated March 7, 2000 was reinstated.

• Right to Appeal the Amended Decision: Under Section 2, Rule 36 of the Rules of Court, a judgment or final order becomes final and executory if no appeal or motion for new trial or reconsideration is filed within the period provided by the Rules. Before a judgment becomes final and executory, it may be amended; upon finality, the court loses its jurisdiction to amend, modify, or alter the same. This is the principle of immutability of final judgment, subject only to a few exceptions: correction of clerical errors, nunc pro tunc entries which cause no prejudice to any party, or where the judgment is void. None of these exceptions were present in this case.

The Court noted that petitioners received the March 7, 2000 Decision on April 24, 2000 and had until May 9, 2000 to file an appeal or a motion for new trial or reconsideration. During this period, petitioners filed instead a petition for relief from judgment on May 4, 2000, which the trial court denied. The petition for relief from judgment was not the proper remedy because it is an extraordinary remedy available only if there are no other remedies; the available remedies were the filing of an appeal, motion for reconsideration, or motion for new trial. Thus, the petition for relief from judgment did not toll the running of the reglementary period, and the March 7, 2000 Decision became final and executory after the lapse thereof.

The Court further held that it was not necessary to amend the original decision holding the petitioners, Marlun Lisbos, and the insurance company solidarily liable. In an action based on quasi-delict, the liability of the employer is direct and primary, subject to the defense of due diligence in the selection and supervision of the employee. Thus, even if the driver was included albeit not served with summons, petitioners are directly and primarily liable. Petitioners Aguila and Reyes, as employer and registered owner or possessor-operator of the van, respectively, are solidarily liable in accordance with Article 2180 in relation to Articles 2184 and 2194 of the Civil Code. As for petitioners' plea for substantial justice, the Court reminded litigants that the Rules of Court are not mere tools that they can readily use or discard to serve their own purpose, and that utter disregard for the rules cannot be rationalized by merely harking on the policy of liberal construction.

• Immutability of Final Judgment — A judgment that has become final and executory can no longer be amended, modified, or altered by the court that rendered it, except for correction of clerical errors, nunc pro tunc entries which cause no prejudice to any party, or where the judgment is void. The Court applied this doctrine to declare the Amended Decision null and void for lack of jurisdiction, since the original March 7, 2000 Decision had already become final and executory when the trial court attempted to substantially alter it by deleting the name of Marlun Lisbos.

• Petition for Relief from Judgment as an Extraordinary Remedy — A petition for relief from judgment is an extraordinary remedy available only if there are no other remedies, such as an appeal, motion for reconsideration, or motion for new trial. The Court held that because petitioners had these other remedies available, their petition for relief from judgment was improper and did not toll the running of the reglementary period for appeal.

• Direct and Primary Liability of the Employer in Quasi-Delict — In an action based on quasi-delict, the liability of the employer is direct and primary, subject to the defense of due diligence in the selection and supervision of the employee. The Court applied this principle to hold that even if the driver was included in the original decision albeit not served with summons, the petitioners, as employer and registered owner or possessor-operator of the van, were directly and primarily liable, making the amendment of the original decision unnecessary.

• "Upon finality of the judgment, the court loses its jurisdiction to amend, modify or alter the same." — This passage states the core principle of immutability of final judgment, which is the ratio decidendi of the case, explaining why the trial court's Amended Decision was declared void.

• "Although the rule that a judgment that becomes final and executory cannot be disturbed admits of exceptions, none of those are present in this case." — This passage confirms that the Court considered the recognized exceptions to the immutability doctrine but found none applicable to the facts, reinforcing the reinstatement of the original decision.

• "In an action based on quasi-delict, the liability of the employer is direct and primary, subject to the defense of due diligence in the selection and supervision of the employee." — This passage articulates the substantive law principle that made the trial court's amendment of the original decision unnecessary, as the petitioners were directly and primarily liable regardless of the driver's inclusion in the judgment.

• Echegaray vs. Secretary of Justice, G.R. No. 132601, January 19, 1999, 301 SCRA 96 — Cited for the principle that upon finality of the judgment, the court loses its jurisdiction to amend, modify, or alter the same.
• Aboitiz Shipping Employees Association vs. Trajano, G.R. No. 112955, September 1, 1997, 278 SCRA 387 — Cited for the exceptions to the principle of immutability of final judgment: correction of clerical errors, nunc pro tunc entries, or void judgments.
• Natalia Realty, Inc. vs. Court of Appeals, G.R. No. 126462, November 12, 2002, 391 SCRA 370 — Cited for the principle of immutability of final judgment and its exceptions.
• Navarro vs. National Labor Relations Commission, G.R. No. 116464, March 1, 2000, 327 SCRA 22 — Cited for the rule that any amendment or alteration made which substantially affects a final and executory judgment is null and void for lack of jurisdiction.
• SGMC Realty Corporation vs. Office of the President, G.R. No. 126999, August 30, 2000, 339 SCRA 275 — Cited together with Navarro for the same rule on nullity of amendments to final judgments.
• Construction Development Corporation of the Philippines vs. Estrella, G.R. No. 147791, September 8, 2006 — Cited for the principle that in an action based on quasi-delict, the liability of the employer is direct and primary, subject to the defense of due diligence in the selection and supervision of the employee.
• Prudential Guarantee and Assurance, Inc. vs. Court of Appeals, G.R. No. 146559, August 13, 2004, 436 SCRA 478 — Cited for the reminder that litigants should not, after resorting to a wrong remedy, cry for liberal construction of the rules.

• Section 2, Rule 36, Rules of Court — Provides that a judgment or final order becomes final and executory if no appeal or motion for new trial or reconsideration is filed within the time provided in the Rules. The Court applied this provision to determine that the March 7, 2000 Decision became final and executory after petitioners failed to file a proper appeal or motion within the reglementary period.
• Article 2180, Civil Code — Provides that employers shall be liable for damages caused by their employees acting within the scope of their assigned tasks. The Court applied this provision to hold petitioners Aguila and Reyes solidarily liable as employer and registered owner or possessor-operator of the van.
• Article 2184, Civil Code — Provides that in motor vehicle mishaps, the owner is solidarily liable with his driver if the former, who was in the vehicle, could have, by the use of due diligence, prevented the misfortune; if the owner was not in the motor vehicle, the provisions of Article 2180 are applicable. The Court cited this provision in relation to Article 2180 to establish the basis of petitioners' solidary liability.
• Article 2194, Civil Code — Provides that the responsibility of two or more persons who are liable for a quasi-delict is solidary. The Court applied this provision to affirm the solidary liability of the petitioners.

• Justice Antonio T. Carpio
• Justice Conchita Carpio Morales
• Justice Dante O. Tinga
• Justice Presbitero J. Velasco, Jr.

N/A — No dissenting opinions are noted in the provided case text.