Supervening event to stop a final judgment

Indeed, the well-settled principle of immutability of final judgments demands that once a judgment has become final, the winning party should not, through a mere subterfuge, be deprived of the fruits of the verdict.[1] There are, however, recognized exceptions to the execution as a matter of right of a final and immutable judgment, one of which is the existence of a supervening event.[2] "A supervening event is a fact which transpires or a new circumstance which develops after a judgment has become final and executory. This includes matters which the parties were unaware of prior to or during trial because they were not yet in existence at that time."[3] To be sufficient to stay or stop the execution, a supervening event must create a substantial change in the rights or relations of the parties which would render execution of a final judgment unjust, impossible or inequitable making it imperative to stay immediate execution in the interest of justice.[4]

[1] Gomez v. Hon. Presiding Judge, RTC, Br. 15, Ozamis City, 319 Phil. 555, 562 (1995); Johnson & Johnson (Phils.), Inc., v. CA, 330 Phil. 856, 871 (1996).

[2] Natalia Realty, Inc. v. Court of Appeals, 440 Phil. 1, 23 (2002).

[3] Dy v. Bibat-Palamos, G.R. No. 196200, September 11, 2013, 705 SCRA 613, 626.

[4] Silverio, Jr. v. Filipino Business Consultants, Inc., 504 Phil. 150, 162 (2005).

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