Commissioner of Customs vs. Agfha Incorporated

A final and executory judgment can no longer be modified in any respect, including the computation and rates of legal interest, under the doctrine of immutability and inalterability of a final judgment.

In February 1993, the Bureau of Customs seized a shipment from Agfha Incorporated. The shipment was subsequently lost while in the Bureau's custody, prompting Agfha to seek the shipment's value from the Commissioner of Customs.

• Seizure and Loss: In February 1993, the Bureau of Customs seized a shipment belonging to Agfha Incorporated. The shipment was lost while in the custody of the Bureau of Customs.
• CTA Ruling on Liability and Interest: The Court of Tax Appeals Second Division (CTA-2D) held the Commissioner of Customs liable for the value of the lost shipment amounting to US$160,348.08, payable in Philippine currency at the exchange rate prevailing at the time of actual payment, subject to the payment of prescribed taxes and duties. The CTA-2D imposed legal interest at 6% per annum computed from February 1993 up to the finality of the Resolution, and 12% per annum from finality until the value of the shipment was fully paid.
• Affirmance by Higher Courts: The CTA En Banc dismissed the petitioner's appeal and affirmed the CTA-2D Resolution in toto on February 25, 2009. The Supreme Court affirmed the CTA En Banc Decision on March 28, 2011.
• Inadvertent Omission: While the Supreme Court's March 28, 2011 Decision affirmed the CTA rulings, its dispositive portion omitted the specific directives regarding the 6% and 12% legal interest rates previously imposed by the CTA-2D. The body of the Supreme Court Decision contained no discussion or rationalization intending to delete the interest on the petitioner's liability.
• Motion for Clarification: Respondent filed a Motion for Clarification/Correction, asserting that the omission was inadvertent and praying that the dispositive portion be corrected to include the awarded interest rates.

• Commencement of Interest: Petitioner argued that the computation of legal interest on the value of the lost shipment must be reckoned from August 13, 2004, the date respondent made a formal judicial demand for the value of its lost shipment, rather than from February 1993, the date of seizure. Petitioner asserted that respondent is entitled to 6% per annum legal interest from August 13, 2004 until the finality of the CTA decision, and 12% per annum thereafter until full payment.

• Inadvertent Omission: Respondent countered that the omission of the interest rates in the Supreme Court's dispositive portion was simply due to inadvertence, given the absence of any discussion in the body of the decision intended to delete the interest on the petitioner's liability.
• Clarification Requested: Respondent prayed that the Supreme Court's March 28, 2011 Decision be clarified and corrected to include the 6% and 12% rates of interest on petitioner's obligation as awarded by the CTA-2D.

• Immutability of Judgment: Whether the interest rates imposed by the CTA-2D and affirmed by the CTA En Banc should be deemed included in the Supreme Court's final decision despite their inadvertent omission in the dispositive portion.
• Commencement of Legal Interest: Whether the computation of legal interest should commence from the date of seizure (February 1993) or the date of formal judicial demand (August 13, 2004).

• Immutability of Judgment: The motion for clarification was granted. The omission of the interest rates in the Supreme Court's dispositive was merely inadvertent, as the decision affirmed the CTA-EB ruling which had previously affirmed the CTA-2D resolution in toto. Because the CTA-2D Resolution was affirmed with finality, its pronouncement on the payment of interest was sustained. Following the doctrine of immutability and inalterability of a final judgment, the decision can no longer be modified in any respect.
• Commencement of Legal Interest: The computation of legal interest must commence from February 1993, as originally ruled by the CTA-2D. Petitioner's stance of computing the legal interest from August 13, 2004, the date of judicial demand, is barred by the final and executory character of the CTA-2D Resolution. Accordingly, respondent is entitled to legal interest from February 1993 until the full amount of the obligation is paid.

• Doctrine of Immutability and Inalterability of a Final Judgment — A final and executory judgment can no longer be modified, in any respect, either by the court which rendered it or even by the Supreme Court. Applied to bar the petitioner's attempt to change the commencement date of legal interest from February 1993 to August 2004, and to confirm that the interest rates omitted inadvertently in the Supreme Court's dispositive remain an integral part of the final and executory CTA judgment.

• "Following the doctrine of immutability and inalterability of a final judgment, the said decision can no longer be modified, in any respect, either by the court which rendered it or even by this Court." — Reiterating the prohibition against altering a final judgment, applied here to preserve the CTA-2D's ruling on the commencement date and rates of legal interest.

Carpio (Chairperson), Peralta, Bersamin, and Abad, JJ.