SC: Everything must come to an end, even litigation


The Court resolves to GRANT petitioner's Motion for Extension of Time of thirty (30) days from the expiration of the reglementary period on September 27, 2018 within which to file her Petition for Review on Certiorari.

After a judicious review of petitioner's allegations and in accordance with Rule 45 and other related provisions of the Rules of Court, the Court further resolves to DENY the present Petition for Review on Certiorari for failure of the petitioner to show any reversible error on the part of the Court of Appeals (CA) in rendering the assailed Decision[1] and Resolution dated June 20, 2018 and August 31, 2018, respectively, in CA-G.R. SP No. 08311.
Petitioner posits that the CA committed serious error in applying the doctrine of immutability of judgments. She further argues that the negligence of her counsel in belatedly filing the Motion for Reconsideration should not bind her for it would cause great injustice and deprive her of her family home.

The contentions are untenable. As correctly found by the CA, petitioner failed to timely file a Motion for Reconsideration of the Office of the President's (OP) Decision dated November 7, 2013 which petitioner received, through her counsel of record, on November 27, 2013. Interestingly, petitioner's Motion for Reconsideration was filed only after one (1) year and three (3) months or on February 12, 2015. By then, the OP's Decision had long attained finality and thus, immutable. Here, as the CA puts it, petitioner lost her right to file her Motion for Reconsideration not because she was bound by the acts of her counsel, but rather because she was bound by her own.[2] The Court stresses that procedural rules should be treated with utmost respect and due regard since they are designed to facilitate the adjudication of cases and in the administration of justice. The parties to a case are thus enjoined to abide strictly by the rules and while there have been some instances wherein this Court allowed a relaxation in the application of the rules, this flexibility was never intended to forge a bastion for erring litigants to violate the rules with impunity. Petitioner was clearly at fault for not following up on her case. In fact, it took her more than a year to resume interest in her case.

All things must come to an end and legal disputes are no exception. It is a fundamental principle that a judgment that lapses into finality becomes immutable, unalterable and may no longer be modified. This principle, known as the doctrine of immutability of judgment, has a two-fold purpose: (1) to avoid delay in the administration of justice; and thus, procedurally, to make orderly the discharge of judicial business; and (2) to put an end to judicial controversies, even at the risk of occasional errors, which is precisely why courts exist.

The said rule, however, like any other rule, admits of exceptions, namely: (1) the correction of clerical errors; (2) the so-called nunc pro tunc entries which cause no prejudice to any party; (3) void judgments; and (4) whenever circumstances transpire after the finality of the decision rendering its execution unjust and inequitable. Jurisprudence is replete with recognized exceptions to the rule but none exists in petitioner's case.

ACCORDINGLY, the Court resolves to AFFIRM the assailed Decision and Resolution dated June 20, 2018 and August 31, 2018, respectively, in CA-G.R. SP No. 08311.

SO ORDERED. Bersamin, J., designated as Acting Chairperson per Special Order No. 2606 dated October 10, 2018; Gesmundo, J., designated as Additional Member per Special Order No. 2607 dated October 10, 2018.

[1] Rollo, pp. 51-58; penned by Associate Justice Edgardo T. Lloren and concurred in by Associate Justices Ruben Reynaldo G. Roxas and Walter S. Ong.