Supervening Event as exception to immutability of judgment

When a judgment attains finality, it becomes immutable and unalterable, resisting even correction due to perceived errors of law or fact. Execution of the judgment becomes a matter of course. In Mercury Drug Corp. v. Spouses Huang:[1]

A final and executory judgment produces certain effects. Winning litigants are entitled to the satisfaction of the judgment through a writ of execution. On the other hand, courts are barred from modifying the rights and obligations of the parties, which had been adjudicated upon. They have the ministerial duty to issue a writ of execution to enforce the judgment.

It is a fundamental principle that a judgment that lapses into finality becomes immutable and unalterable. The primary consequence of this principle is that the judgment may no longer be modified or amended by any court in any manner even if the purpose of the modification or amendment is to correct perceived errors of law or fact. This principle known as the doctrine of immutability of judgment is a matter of sound public policy, which rests upon the practical consideration that every litigation must come to an end. [Emphasis ours.]

The rationale behind the rule was further explained in Social Security System v. Isip, thus:

The doctrine of immutability and inalterability of a final 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, at the risk of occasional errors, which is precisely why courts exist. Controversies cannot drag on indefinitely. The rights and obligations of every litigant must not hang in suspense for an indefinite period of time.[2] (Citations omitted)

One exception to the immutability of judgments is when there exists a supervening event, or "facts which transpire after judgment has become final and executory or to new circumstances which developed after the judgment has acquired finality, including matters which the parties were not aware of prior to or during the trial as they were not yet in existence at that time."[3] A supervening event renders the execution of the judgment impossible or unjust,[4] requiring new relief to be granted as the new facts or circumstances warrant.[5]

For a supervening event to be an exception to the execution of a final judgment, the following must concur: first, the fact or circumstance must occur after the judgment became final and executory; and second, the fact or circumstance must be shown to affect or change the judgment's substance, making its execution inequitable.[6]

The Supreme Court has upheld the stay of execution of final and executory judgments in cases where orders for reinstatement to a previous position were no longer feasible,[7] or where court decisions changing the execution of prior ones are promulgated.[8]

Conversely, the High Court does not consider to be supervening event facts and circumstances that arose before the judgment became final and executory, but were only raised after.[9] Further, if the fact or circumstance did not materially change the parties' situation and did not materially affect the execution of the judgment, it cannot be considered a supervening event.[10] An instance would be the death of a party, as they may be substituted by heirs.[11]

[1] 817 Phil. 434 (2017) [Per J. Leonen, Third Division].

[2] Id. at 445-446.

[3] Natalia Realty Inc. v. Court of Appeals (Former Ninth Division), 440 Phil. 1, 23 (2002) [Per J. Carpio, First Division] citing Clavano v. Housing and Land Use Regulatory Board, 428 Phil. 208 (2002) [Per J. Bellosillo, First Division].

[4] De Luna v. Kayanan, 158 Phil. 707 (1974) [Per J. Antonio, Second Division].

[5] Abellana v. Dosdos, 121 Phil. 241 (1965) [Per J. Makalintal, En Banc].

[6] Mercury Drug Corp. v. Spouses Huang, 817 Phil. 434 (2017) [Per J. Leonen, Third Division].

[7] City of Butuan v. Hon. Ortiz, 113 Phil. 636 (1961) [Per J. Labrador, En Banc].

[8] Heirs of Maravilla v. Tupas, 795 Phil. 145 (2016) [Per J. Peralta, Third Division]; and Roman Catholic Bishop of Caceres v. Heirs of Abella, 512 Phil. 408 (2005) [Per J. Austria-Martinez, Second Division].

[9] Clavano v. Housing and Land Use Regulatory Board, 428 Phil. 208 (2002) [Per J. Bellosillo, First Division].

[10] NPC Drivers and Mechanics Association v. The National Power Corporation, 737 Phil. 210 (2014) [Per J. Brion, Special Third Division].

[11] Ramirez v. Court of Appeals, G.R. No. 85469, March 18, 1992 [Per J. Nocon, Second Division].