In re Adoption of Karen Herico Licerio

A final and executory judgment may be altered to harmonize it with justice and the facts when supervening events render its execution unjust or impossible, and the court may admit evidence of such new circumstances and grant the appropriate corrective relief.

Spouses Joel H. Borromeo and Carmen H. Licerio, who already had two legitimate minor children, sought to jointly adopt Karen Herico Licerio, the illegitimate minor daughter of Carmen. They filed a verified petition for adoption before the Regional Trial Court of Marikina City.

• The Adoption: Petitioners Joel H. Borromeo and Carmen H. Borromeo (née Licerio), spouses with two legitimate children, jointly filed a verified petition to adopt Karen Herico Licerio, Carmen’s illegitimate minor daughter. The petition was docketed as JDRC Case No. 05-1119-MK before the RTC of Marikina City.
• The Adoption Decree: On June 27, 2006, the RTC of Marikina City granted the petition, declaring Karen the legitimate child and heir of the spouses, changing her name to Karen Licerio Borromeo, and directing the “City Civil Registrar of Quezon City” to annotate the original birth certificate, issue a new one without notation, and seal the original record.
• Discovery of Duplicate Registration: On July 12, 2006, when petitioners presented the decree to the Quezon City Civil Registrar, they were informed that Karen’s birth was also registered in Caloocan City. The Quezon City office advised that implementation required cancellation of the Caloocan registration.
• Proceedings in Caloocan City: Petitioners filed a petition for cancellation of the Caloocan birth registration. In an Order dated May 23, 2012, the RTC of Caloocan City directed the correction of entries—changing the child’s recorded name from “Karen Licerio Torres” to “Karen Licerio” and the parents’ marriage status to “not married”—but did not cancel the birth certificate, leaving the duplicate registration intact.
• Motion to Correct the Adoption Decision: With the Quezon City registrar still unable to act and the Caloocan registration uncancelled, petitioners filed a “Motion to Correct” on February 19, 2013, seeking to replace “City Civil Registrar of Quezon City” with “City Civil Registrar of Caloocan City” in the dispositive portion of the June 27, 2006 decision.
• RTC Denial: The RTC of Marikina City denied the motion on May 23, 2013, holding that the decision had become final and executory and was therefore immutable and unalterable. It ruled that none of the recognized exceptions—correction of clerical errors, nunc pro tunc entries, or void judgments—applied, as the duplicitous registration had never been raised during the adoption proceedings and the evidence showed the child was born in Quezon City. The motion for reconsideration was denied on July 1, 2013.

• Non-applicability of Rule 39: Petitioners maintained that adoption and correction of entries in the civil registry are special proceedings, and Section 6, Rule 39 of the Rules of Court—which governs execution of final judgments in ordinary civil actions—does not strictly apply.
• Harmonization with Substantial Justice: Petitioners argued that even final judgments may be modified or altered to harmonize them with justice and the facts, particularly where supervening events make execution impossible or inequitable.

• The Office of the Solicitor General agreed that adoption and correction of entries are special proceedings to which Section 6, Rule 39 does not apply, but contended that the proper remedy was a separate action to determine the relevance and effect of the Caloocan birth record.

• Immutability of Judgment: Whether the RTC of Marikina City erred in denying the Motion to Correct on the ground that the June 27, 2006 decision had become final and immutable, despite the supervening impossibility of enforcement.

• Immutability of Judgment: The denial was erroneous. The doctrine of immutability of judgment admits of a fourth exception—when circumstances transpiring after finality render execution unjust or impossible. Here, the belated discovery of Karen’s duplicitous birth registration and the refusal of the RTC of Caloocan City to cancel that registration made enforcement of the adoption decree through the Quezon City registrar impossible. Because the supervening facts directly affected the rights of the parties and frustrated the implementation of a valid adoption, the trial court was authorized to admit evidence of the new circumstances, determine the correct civil registrar, and alter the decision solely as to that ministerial detail. Requiring petitioners to initiate an entirely new action would impose unnecessary hardship and elevate procedural technicality over substantial justice.

• Doctrine of Immutability of Judgment (and its exceptions) — A decision that has attained finality is immutable and unalterable and may no longer be modified even to correct erroneous conclusions of fact or law. The recognized exceptions are: (1) correction of clerical errors; (2) nunc pro tunc entries causing no prejudice; (3) void judgments; and (4) circumstances transpiring after finality that render execution unjust and inequitable. The Court applied the fourth exception because the post-finality surfacing of the Caloocan registration made execution impossible and would have defeated the adoption’s purpose if left uncorrected.
• Power to Modify Judgments Based on Supervening Facts — When an event or circumstance affecting the rights of the parties is established after a judgment becomes final, the court may admit evidence of such new facts, suspend execution, and grant the relief warranted by the changed situation. This principle enabled the trial court to correct the designation of the implementing civil registrar without reopening the merits of the adoption itself.
• Primacy of Substantial Justice over Strict Procedural Rules — Rules of procedure are tools to facilitate the attainment of justice; their rigid application, resulting in technicalities that frustrate rather than promote substantial justice, must be eschewed. The Court invoked this doctrine to allow the modification of a final judgment rather than relegating the parties to a new and duplicative suit.

• “Under the doctrine of finality of judgment or immutability of judgment, a decision that has acquired finality becomes immutable and unalterable, and may no longer be modified in any respect, even if the modification is meant to correct erroneous conclusions of fact and law.”
• “When after judgment has been rendered and the latter has become final, facts and circumstances transpire which render its execution impossible or unjust, the interested party may ask the court to modify or alter the judgment to harmonize the same with justice and the facts.”
• “After a judgment has become final, if there is evidence of an event or circumstance which would affect or change the rights of the parties thereto, the court should be allowed to admit evidence of such new facts and circumstances, and thereafter suspend execution thereof and grant relief as the new facts and circumstances warrant.”
• “Rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application, which would result in technicalities that tend to frustrate rather than promote substantial justice, must always be eschewed.”

• Mendoza v. Fil-Homes Realty Development Corp., 681 Phil. 621 (2012) — Enumerated the four exceptions to the doctrine of immutability of judgment; the Court relied on this framework to identify the applicable fourth exception.
• City of Butuan v. Ortiz, 113 Phil. 636 (1961) — Established the rule that a final judgment may be modified when supervening facts and circumstances make execution impossible or unjust; applied directly to the duplicate registration problem.
• Candelario v. Canizares, 114 Phil. 672 (1962) — Held that courts may admit evidence of post-finality events affecting the rights of parties and grant relief accordingly; cited to justify the reception of new evidence by the trial court.
• Barnes v. Judge Padilla, 482 Phil. 672 (2004) — Emphasized that procedural rules must yield to substantial justice and that the power to relax finality doctrines is available in compelling circumstances; used to support the remand instead of requiring a new action.

• Rule 39, Section 6, Rules of Court — Discussed in the parties’ arguments regarding execution of final judgments; the Court noted that adoption is a special proceeding not strictly governed by the execution rules for ordinary civil actions, reinforcing the application of an exception to immutability.

Carpio, J. (Chairperson), Perlas-Bernabe, J., Caguioa, J., and J. Reyes, Jr., J.