DOCTRINE OF FINALITY OF JUDGMENT

The importance of the doctrine of the finality of judgment has always been emphasized by the Supreme Court.

In Pasiona, Jr. v. Court of Appeals, G.R. No. 165471, July 21, 2008, 559 SCRA 137, 145-146, the Supreme Court has expounded on the said doctrine, thus:

The Court re-emphasizes the doctrine of finality of judgment. In Alcantara v. Ponce, G.R. No. 131547, December 15, 2005, 478 SCRA 27, the Court, citing its much earlier ruling in Arnedo v. Llorente, 18 Phil. 257 (1911)stressed the importance of said doctrine, to wit:  

It is true that it is the purpose and intention of the law that courts should decide all questions submitted to them "as truth and justice require," and that it is greatly to be desired that all judgments should be so decided; but controlling and irresistible reasons of public policy and of sound practice in the courts demand that at the risk of occasional error, judgments of courts determining controversies submitted to them should become final at some definite time fixed by law, or by a rule of practice recognized by law, so as to be thereafter beyond the control even of the court which rendered them for the purpose of correcting errors of fact or of law, into which, in the opinion of the court it may have fallen. The very purpose for which the courts are organized is to put an end to controversy, to decide the questions submitted to the litigants, and to determine the respective rights of the parties. With the full knowledge that courts are not infallible, the litigants submit their respective claims for judgment, and they have a right at some time or other to have final judgment on which they can rely as a final disposition of the issue submitted, and to know that there is an end to the litigation. (Alcantara v. Ponce; Arnedo v. Llorente, 18 Phil. 257 (1911).

Then, in Juani v. Alarcon, G..R. No. 166849, September 5, 2006, 501 SCRA 135. it was held, thus:

This doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice. In fact, nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land.

Again, in Dinglasan v. Court of Appeals, G.R. No. 145420, September 19, 2006, 502 SCRA 253, the Supreme Court declared that:

After the judgment or final resolution is entered in the entries of judgment, the case shall be laid to rest. x x x

x x x x

The finality of decision is a jurisdictional event which cannot be made to depend on the convenience of the party. To rule otherwise would completely negate the purpose of the rule on completeness of service, which is to place the date of receipt of pleadings, judgment and processes beyond the power of the party being served to determine at his pleasure.

The said doctrine, however, is applicable only when the judgment or decision is valid.

In Pascual vs. Pascual, the Supreme Court affirmed the ruling of the CA that the judgment in question is void since the RTC did not acquire jurisdiction over the person of the respondent since it is a well-entrenched principle that a void judgment can never become final.

As ruled by this Court in Metropolitan Bank & Trust Company v. Alejo, G.R. No. 141970, September 10, 2001, 364 SCRA 812, 823.

In Leonor v. Court of Appeals^, 326 Phil. 74, 88 (1996). and Arcelona v. Court of Appeals, 345 Phil. 250, 287, the we held thus:

A void judgment for want of jurisdiction is no judgment at all. It cannot be the source of any right nor the creator of any obligation. All acts performed pursuant to it and all claims emanating from it have no legal effect. Hence, it can never become final and any writ of execution based on it is void: "x x x it may be said to be a lawless thing which can be treated as an outlaw and slain at sight, or ignored wherever and whenever it exhibits its head."

Verily, a void judgment can never become final. (CONSTANTINO A. PASCUAL, vs. LOURDES S. PASCUAL, G.R. No. 171916, December 4, 2009, PERALTA, J.)