By Atty. Julius Gregory B. Delgado
MONTEHERMOSO, ET. AL. VS. BAUTO, ET AL., G.R. NO. 246553 (02 DECEMBER 2020):
RESTATEMENT OF THE DOCTINE OF FINALITY OR IMMUTABILITY OF JUDGMENT
There is a legal maxim in Latin which states that Interest Rei Publicae Ut Finis Sit Litium or in the interest of the society, litigation must come to an end. In a Decision issued on 02 December 2020 in G.R. No. 246553 entitled “Montehermoso, et al. vs. Bauto, et al.”, the Supreme Court came out with a strong restatement against litigants and lawyers who attempt to trifle the doctrine of finality of judgment or immutability of judgment. The Court succinctly held:
“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, and whether it be made by the court that rendered it or by the Highest Court of the land. Any act which violates this principle must immediately be struck down.”
The case arose from a complaint for cancellation of title, reconveyance and damages filed by the respondents Romeo Batuto and Amel Batuto against the petitioners Montehermosos because their property, consisting of an area of 44,410 square meters, was erroneously included in the Original Certificate of Title No. 5781 of the latter. In a Decision dated 08 March 2015, the trial court granted the Complaint and ordered the reconveyance of the Property to the Batutos. However, the Montehermosos lodged a barrage of court actions. First, they appealed the Decision before the Court of Appeals which denied the same. Second, they appealed the denial of their Appeal by the Court of Appeals before the Supreme Court but were unsuccessful. Third, they filed a Petition for Relief of Judgment before the Court of Appeals which denied the same. Fourth, they elevated the denial of their Petition for Relief of Judgment before the Supreme Court to no avail. Fifth, they filed a Petition for Annulment of Judgment before the Court of Appeals which again denied the same. Finally, the instant case for a Petition for Review on Certiorari was filed to question the denial of their Annulment of Judgment Case in the Court of Appeals.
The Supreme Court was furious in restating the doctrine on finality or immutability of judgment. The Court, citing Spouses Aguilar vs. Manila Banking Corporation, G.R. No. 157911 (19 September 2006), held:
“It is an important fundamental principle in the judicial system that every litigation must come to an end. Access to the courts is guaranteed. But there must be a limit thereto. Once a litigant’s rights have been adjudicated in a valid and final judgment of a competent court, he should not be granted an unbridled license to come back for another try. The prevailing party should not be harassed by subsequent suits. For, if endless litigations were to be encouraged, then unscrupulous litigants will multiply to the detriment of the administration of justice.”
Citing the case of Spouses Aguilar vs. The Manila Banking Corporation, supra, the Supreme Court also took the opportunity to remind lawyers that, as officers of the court, their primary duty is for the orderly administration of justice and not to unduly impede the same. The Court held that it is the duty of the lawyer to advise his client, ordinarily a layman on the intricacies and vagaries of the law, on the merit or lack of merit of his case. If the client’s cause is defenseless, he must advise the client rather than traverse the impossible. The Court held that “a lawyer must resist the whim and caprices of his client and temper his client’s propensity to litigate.”
The Court then cited the cases of Central Surety and Insurance Company vs. Planters Products, Inc., G.R. No. 149053 (07 March 2007), and Reyes vs. Alsons Development and Investment Corporation, G.R. No. 153936 (02 March 2007), wherein the Supreme Court tripled the costs for clear forum shopping and filing of dilatory motions and actions. The Court also warned the counsel in those cases. In the case of Reyes vs. Alsons Development and Investment Corporation, supra, the Court even held that these frivolous actions “unduly taxed the manpower and financial resources not only of the judiciary, but those of the prevailing party as well.”
In the instant case of Montehermoso, et al. vs. Batuto, et al., supra, the Supreme Court held:
“Here, petitioners, too, should now stop making a mockery of the judicial system through their pernicious attempts to revive the trial court’s long settled and implemented decision. A violation of this injunction will be sanctioned accordingly.
As for petitioners’ counsel, Atty. Belinda M. Nagui, she is reminded of her primordial duty as an officer of the court who must see to it that the orderly administration of justice must never be unduly impeded. As such, she must resist the whims and caprices of her clients, and temper her clients’ propensities to litigate. Her oath to uphold the cause of justice is superior to her duty to her client; its primacy is indisputable.”
In a litigation, there is always a victor and a losing side. Usually, it is the one which case tilts the scales of justice because under the law and jurisprudence, his side is the one which has merits. Once final and executory, a litigant and his counsel do not have the unbridled discretion to file anything they want to stop the execution or implementation of the legal victory. To do so would invite imposition of triple costs to the litigants and even administrative case against the lawyer. The principle of immutability or finality of judgment is precisely to ensure that only meritorious cases remain pending and that the precious time and resources of our courts could be spent on these cases.