There is a difference between an amended judgment and a supplemental judgment. In an amended and clarified judgment, the lower court makes a thorough study of the original judgment and renders the amended and clarified judgment only after considering all the factual and legal issues. The amended and clarified decision is an entirely new decision which supersedes the original decision.
On the other hand, following the Supreme Court's differentiation of a supplemental pleading from an amending pleading, it can be said that a supplemental decision does not take the place or extinguish the existence of the original. As its very name denotes, it only serves to bolster or adds something to the primary decision. A supplement exists side by side with the original. It does not replace that which it supplements (ASSOCIATED ANGLO-AMERICAN TOBACCO CORPORATION and FLORANTE DY, vs. COURT OF APPEALS, HON. CRISPIN C. LARON, G.R. No. 167237, April 23, 2010 DEL CASTILLO, J.).
