Implementation of judgment based on dispositive portion

A judgment should be implemented according to the terms of its dispositive portion is a long and well-established rule.[1] As such, where the writ of execution is not in harmony with and exceeds the judgment which gives it life, the writ has pro tanto no validity.[2]

A companion to this rule is the principle of immutability of final judgments, which states that a final judgment may no longer be altered, amended or modified, even if the alteration, amendment or modification is meant to correct what is perceived to be an erroneous conclusion of fact or law and regardless of what court renders it. Any attempt to insert, change or add matters not clearly contemplated in the dispositive portion violates the rule on immutability of judgments.[3]

However, like any other rule, this principle has 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.[4]

[a] Session Delights v. CA (G.R. No. 172149; February 8, 2010).
[b] 143 things to know before reading SC cases - Project Jurisprudence.
[c] Desmoparan v. People (G.R. No. 233598. March 27, 2019).

[1] Lim v. HMR Philippines, Inc., G.R. No. 201483, August 4, 2014, 731 SCRA 576, 590.
[2] Green Acres Holdings, Inc. v. Cabral, G.R. Nos. 175542 and 183205, June 5, 2013, 697 SCRA 266, 285, citing Ingles v. Cantos, 516 Phil. 496, 506 (2006).
[3] Lim v. HMR Philippines, Inc., supra note 1, at 590.
[4] Ptyce Corporation v. China Banking Corporation, G.R. No. 172302, February 18, 2014, 716 SCRA 207, 222, citations omitted.

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