Judicial review of quasi-judicial agencies

Notwithstanding our disagreement with the decision of the respondent court and the ruling of the Secretary of Justice that a novation by substitution of creditor has taken place, we opt not to disturb the Resolution of the respondent Secretary of Justice dated January 23, 1992 finding a prima facie case against the petitioner in as much as it had already become final. It appears that petitioner filed two motions for reconsideration to the said resolution, the first one on February 6, 1992 and the second one in June 2, 1992. These two motions were, however, denied by the respondent Secretary of Justice, the last denial was contained in a Resolution dated June 25, 1992 which was received by petitioner on July 9, 1992. Petitioner made no prompt attempt to question the said resolutions before the proper forum. It took her almost seventeen months (from July 9, 1992 to February 2, 1994) to challenge the January 23, 1992 Resolution when she filed the petition for certiorari with the respondent court on February 2, 1994, which resolved to affirm the aforesaid resolution of the Secretary of Justice. Petitioner who chose her forum but unfortunately lost her claim is bound by such adverse judgment on account of finality of judgment, otherwise, there would be no end to litigation. Litigation must end and terminate sometime and somewhere, and it is essential to an effective administration of justice that once a judgment has become final, the issue or cause therein should be laid at rest. While the respondent Secretary of Justice was in error in applying the rule on novation in the January 23, 1992 Resolution, such irregularity, however, does not affect the validity of the proceedings in the Department of Justice. Erroneous application of a legal principle cannot bring a judgment that has already attained the status of finality to an absolute nullity under the well entrenched rule of finality of judgment. The basic rule of finality of judgment is grounded on the fundamental principle of public policy and sound practice that at the risk of occasional error, the judgment of court and award of quasi-judicial agencies must become final at some definite date fixed by law. It bears emphasis that the above pronouncement we laid down applies only pro hac vice. This Court in affirming the questioned resolution despite the erroneous application of a legal principle acted according to what the peculiar circumstances of the instant case demand. Its factual setting led us to consider that to sustain the resolution is but the proper action to take in this particular case. [G.R. No. 120817. November 4, 1996]