Arroyo v. CA

Doctrine: Generally, courts may no longer review or modify a final and executory judgment. This is otherwise referred to as the principle of immutability of judgments, which dictates that once a decision becomes final, the enforcement or execution of the judgment becomes a purely ministerial act. This notwithstanding, the doctrine on immutability of judgments admits of the following exceptions: (a) the correction of clerical errors; (b) the so-called nunc pro tunc entries that cause no prejudice to any party; (c) void judgments; and (d) whenever circumstances transpire after the finality of the judgments rendering execution unjust and inequitable.

Facts: The enactment of RA No. 8371 (The Indigenous Peoples’ Rights Act of 1997) merged the Office for the Northern Cultural Communities (ONCC) and Office of Southern Cultural Communities (OSCC) as the organic offices of the National Commission on Indigenous Peoples (NCIP). The functions of the regional and field offices of the ONCC and OSCC were retained under the new organizational structure of the NCIP. The positions of Staff Directors, Bureau Directors, Deputy Executive Directors and Executive Directors, except the positions of Regional Directors and below were phased out. Absorbed personnel were nonetheless subject to the qualifications set by the Civil Service Commission and the Placement Committee created.

Brito who was then the Regional Director for Region V of the OSCC, was temporarily appointed to the same position. On August 31, 2000, Arroyo was appointed as the Regional Director of Region V. Unsatisfied with the appointment of Arroyo and three other appointees, Brito, holding the positions of Bureau Director and Regional Director, initiated a petition for quo warranto to challenge their appointment before the CA. CA partially granted the petition insofar as Brito and his co-petitioner Batay-an were concerned. The CA held that since Sec. 74 of RA No. 8371 did not phase out the Regional Director positions, the incumbent Regional Directors were retained, subject to the qualifications prescribed under Civil Service Rules and the standards set by the newly-created Placement Committee. Since Brito held an Executive Service Officer (CESO) Rank III eligibility, he possessed the necessary qualifications as Regional Director for Region V.

Arroyo moved for the reconsideration of the decision. Pending the resolution of her motion, Arroyo filed a Manifestation with the CA, citing newly discovered evidence supporting her claim that Brito did not obtain a bachelor’s degree, which is an academic qualification for the position fo Regional Director. The Office of the President (OP) affirmed the recommendation of PAGC to hold Brito liable for falsifying his scholastic records. However, CA remained unmoved by these arguments. The motion was denied.

Arroyo did not elevate the matter to the SC for review. This prompted Brito to file a Motion for Entry of Judgment and for the Issuance of a Writ of Execution. Arroyo opposed this motion and argued that the petition for quo warranto was rendered moot and academic by virtue of the decision of the OP. CA found that the decision granting the quo warranto petition had become final and executory. Arroyo filed a Motion for Reconsideration which was denied.

Issue: Whether or not the CA gravely abused its discretion, amounting to lack or excess of jurisdiction, in directing the execution of its decision granting the quo warranto petition of Brito.

Held: Granted. It is true that the execution of a court’s judgment becomes a matter of right upon the expiration of the period to appeal and no appeal was duly perfected. Generally, therefore, courts may no longer review or modify a final and executory judgment. This is otherwise referred to as the principle of immutability of judgments, which dictates that once a decision becomes final, the enforcement or execution of the judgment becomes a purely ministerial act. This notwithstanding, the doctrine on immutability of judgments admits of the following exceptions: (a) the correction of clerical errors; (b) the so-called nunc pro tunc entries that cause no prejudice to any party; (c) void judgments; and (d) whenever circumstances transpire after the finality of the judgments rendering execution unjust and inequitable. The Court applies these exceptions in order to serve the interests of justice. 

In this case, Arroyo invoked the last exception, which relates to supervening events. A supervening event, in order to apply, must rest on proven or certain facts. Hence, Arroyo should establish through competent evidence there are events, which transpired after the finality of the decision altered or modified the parties’ situation in such manner that renders execution of the judgment inequitable, impossible, or unfair. It should directly affect the matter already litigated and settled, or substantially change the rights or relations of the parties. While Arroyo raised the fact that Brito falsified his college degree in her motion for the reconsideration of the quo warranto decision, it was only on October 30, 2007 that the OP declared final its decision to dismiss and disqualify Brito from government service. By then, the period to appeal to the Court has lapsed without Arroyo filing an appeal, and Brito has commenced the execution of the quo warranto decision in his favor. Verily, the supervening event referred to in the present case transpired after the finality of the judgment that Brito sought to execute. 

Lacking the requisite qualifications for the controverted public office or position, the petitioner in a quo warranto proceeding may not raise the lack of qualification of the supposed usurper. This requirement necessarily proceeds from the ultimate relief that is granted to the individual initiating the quo warranto proceeding — which is ousting the incumbent and placing the challenger to the controverted position.

The final and executory judgment of the OP, finding Brito liable for falsification of his bachelor’s degree, has effectively rendered the execution of the quo warranto judgment impossible, inequitable, and unjust.