Definition and Nature of a Judgment
A judgment is a final ruling or order by a court or tribunal that determines the rights and obligations of the parties in a case. It represents the official and final determination of the controversy. A judgment must clearly and distinctly state the facts and the law upon which it is based. Its purpose is to inform the person reading it, especially the parties, how the decision was reached. The judgment is the resolution of the subject matter of the action.
Form and Rendition
A judgment or final order must be in writing, personally and distinctly prepared by the judge, state clearly and distinctly the facts and the law, be signed by the judge, and filed with the clerk of court. The "rendition" of a judgment occurs when the signed judgment is filed with the clerk of court. It is not the pronouncement of the judgment in open court. The date the judgment is filed with the clerk is the date of its rendition.
Finality and Entry
A judgment is considered final if it completely disposes of the case, leaving nothing more to be done. Once a judgment becomes final, it is generally immutable and unalterable. Entry of judgment is the physical act of the clerk of court in recording the judgment in the book of entries of judgment. The date of entry is significant because the judgment becomes final and executory upon its entry, provided no appeal or motion for new trial or reconsideration is timely filed.
Types of Judgments
Various forms of judgments:
- Judgment on the Merits: This is a judgment based upon the substantive rights and duties of the parties as disclosed by the ultimate facts and the law, irrespective of formal or technical objections.
- Judgment by Default: A judgment rendered against a party who fails to answer within the time fixed by the rules.
- Judgment on the Pleadings: This is proper when the answer filed by the adverse party fails to tender an issue or admits the material allegations of the complaint. It is based exclusively on the pleadings.
- Summary Judgment: This is granted upon motion when there is no genuine issue as to any material fact based on the pleadings, affidavits, depositions, and admissions, and the moving party is entitled to judgment as a matter of law. It serves as a procedural device to avoid useless trials by determining if there is a triable issue.
- Several Judgment: A judgment rendered against one or more defendants, but not against all of them.
- Separate Judgment: A judgment that resolves one or more claims for relief in a single action, while other claims (like counterclaims or cross-claims) are still pending. Execution of a separate judgment may be stayed.
- Conditional Judgment: A judgment whose effectivity depends on the happening of a future event.
- Judgment Sin Perjuicio: A brief judgment stating only the dispositive portion, with the detailed reasoning to follow. This practice should be avoided.
- Judgment Nunc Pro Tunc: A judgment entered into the record to reflect what was previously done by the court, typically to correct clerical errors or omissions in the record. It records an act previously done, but does not supply an omitted action.
- Special Judgments: Judgments requiring the performance of a specific act other than the payment of money. Refusal to comply can be punishable by contempt.
Distinguished from Interlocutory Orders
A judgment is distinct from an interlocutory order. A judgment is final and disposes of the case, while an interlocutory order does not finally determine the action but merely resolves incidental matters or is made during the pendency of the action. Interlocutory orders are generally not appealable.
Remedies Against Judgments
Errors in a judgment are classified into errors of judgment and errors of jurisdiction. Errors of judgment are mistakes in the application of law or assessment of facts, correctible by appeal. Errors of jurisdiction occur when the court acts without or in excess of its jurisdiction or with grave abuse of discretion, rendering the judgment void. Errors of jurisdiction are correctible by certiorari. Annulment of judgment under Rule 47 is an extraordinary remedy available when a judgment is void due to lack of jurisdiction or extrinsic fraud, provided the ordinary remedies of new trial, appeal, or petition for relief were lost through no fault of the petitioner.
Execution of Judgments
The execution of a judgment must conform to its dispositive portion. Execution pending appeal is discretionary and requires 'good reasons' shown by the prevailing party. A writ of execution can be quashed on grounds such as improper issuance, defect in substance, payment of debt, or if the property is exempt from execution. Garnishment is a method of executing a judgment against a third party indebted to the judgment obligor. Property exempt from execution includes the judgment obligor's family home or homestead. The rule is that a judgment rendered in accordance with a compromise agreement is executory and not appealable.