Immutability of judgment

By: Atty. Mary Grace S. Tejada on December 11, 2025

ONE of the hallmarks of an effective and efficient administration of justice is the final resolution of legal disputes. As consistently held by the Supreme Court, every litigation must come to an end in the interest of society as a whole.

Central to this principle is the doctrine of immutability of judgments. It is a long-standing and well-recognized principle in the Philippine legal framework and provides that once a decision has acquired finality, it can no longer be modified or altered, even if the modification is intended to rectify an erroneous conclusion of fact or law.

In Marilyn B. Montehermoso, et al. v. Romeo Batuto (GR 246553, Dec. 2, 2020), the Supreme Court explained that the principle of immutability of judgments ensures that the prevailing party in a suit will not be denied the fruits of victory by some scheme devised by the losing party intended to unjustifiably delay the enforcement of the judgment.

Furthermore, in the case of Mercury Drug Corporation v. Spouses Huang (GR 197654, Aug. 30, 2017), the Supreme Court held that the doctrine of immutability of judgment serves a two-fold purpose: first, it avoids delay in the administration of justice and makes orderly the discharge of judicial business; and second, it puts an end to judicial controversies.

However, like any other legal doctrine, the doctrine of immutability of judgment is not one without exceptions. The following are among the well-known exceptions to the rule:

– correction of clerical errors;

– nunc pro tunc entries that cause no prejudice to any party;

– void judgments; and

– whenever circumstances transpire after the finality of the decision, rendering its execution unjust and inequitable.

Clerical errors contemplate typographical errors, arithmetic miscalculations or interchange of words. It may also include inadvertent omission or mistake in the disposition of the case that creates ambiguity. Clerical errors may be corrected without violating the doctrine of immutability of judgment, provided that the correction does not affect the substance of the controversy.

In Felicito Baguio v. Honorable Acting Presiding Judge Rosendo Bandal, Jr. (GR 126442, Dec. 29, 1998), the dispositive portion of a regional trial court decision was amended despite attaining finality to reflect therein the correct lot number of the property subject of the litigation. In allowing the modification, the Supreme Court held that the doctrine of the immutability of judgment was not violated as the error corrected was merely clerical and typographical and did not affect the judgment’s substance.

Nunc pro tunc (Latin for “now for then”) judgments are allowed in cases where there is a need to reflect in the records of the case a judicial action that has been omitted through mistake or inadvertence. Such judgments may be issued only if none of the parties will be prejudiced thereby.

The principle of inalterability of judgment rests on the existence of a final and conclusive judgment. As void judgments can never attain the status of a final and executory judgment, they can be challenged at any time.

Another exception to the immutability of judgment is supervening events. In Jose Clavano, Inc. v. Housing and Land Use Regulatory Board (GR 143781, Feb. 27, 2002), the Supreme Court defined supervening events as facts which transpire after the judgment has become final and executory. It likewise contemplates circumstances which developed after the judgment had acquired finality, including matters which the parties were unaware of before or during the trial, as they were not yet in existence at that time.

In Bani Rural Bank, Inc. v. Teresa de Guzman et al. (GR 170904, Nov. 13, 2013), the Supreme Court considered the strained relationship between the employer and the employee a supervening event justifying the National Relations Commission’s modification of its final resolution from order of reinstatement to payment of separation pay.

As a vital pillar of the legal system, the doctrine of immutability of judgment not only puts an end to what may otherwise be an endless litigation, but it also promotes stability and public confidence in the judicial system.

Mary Grace S. Tejada is an Associate of Mata-Perez, Tamayo & Francisco (MTF Counsel). This article is for general information only and is not a substitute for professional advice where the facts and circumstances warrant. If you have any question or comment regarding this article, you may email the author at info@mtfcounsel.com or visit MTF website at www.mtfcounsel.com

The article was published at the More to Follow Column at The Manila Times on December 11, 2025. Please see this link.

https://www.manilatimes.net/2025/12/11/business/top-business/immutability-of-judgment/2240871