TOPIC Judgement

CASE NO. G.R. No. 164195

DOCTRINE
As a rule, a final judgment may no longer be altered, amended or modified, even if the alteration,
amendment or modification is meant to correct what is perceived to be an erroneous conclusion of fact or
law and regardless of what court, be it the highest Court of the land, rendered it. In the past, however, we
have recognized exceptions to this rule by reversing judgments and recalling their entries in the interest of
substantial justice and where special and compelling reasons called for such actions.

RECIT-READY DIGEST
Petitioners voluntarily offered to sell their lands to the government under Republic Act 6657, otherwise
known as the Comprehensive Agrarian Reform Law (CARL). Government took petitioners’ lands on
December 9, 1996. Land Bank valued the properties atP165,484.47 per hectare, but AFC-HPI rejected the
offer of that amount. Consequently, on instruction of the Department of Agrarian Reform (DAR), Land
Bank deposited for AFC and HPI P26,409,549.86 and P45,481,706.76, respectively, or a total of
P71,891,256.62. Upon revaluation of the expropriated properties, Land Bank eventually made additional
deposits, placing the total amount paid at P411,769,168.32 (P71,891,256.62 + P339,877,911.70), an
increase of nearly five times. Both petitioners withdrew the amounts. Still, they filed separate complaints
for just compensation with the DAR Adjudication Board (DARAB), where it was dismissed, after three
years, for lack of jurisdiction. Petitioners filed a case with the RTC for the proper determination of just
compensation. The RTC ruled in favor of petitioners fixing the valuation of petitioners’ properties at
P103.33/sq.m with 12% interest plus attorney’s fees. Respondents appealed to the Third Division of the
Supreme Court where the RTC ruling was upheld. Upon motion for reconsideration, the Third Division
deleted the award of interest and attorney’s fees and entry of judgment was issued. The just compensation
of which was only settled on May 9, 2008. Petitioners filed a second motion for reconsideration with
respect to denial of award of legal interest and attorney’s fees and a motion to refer the second motion to
the Court En Banc and was granted accordingly, restoring in toto the ruling of the RTC. WON the grant
of the second motion for reconsideration runs counter to the immutability of final decisions? NO. As a
rule, a final judgment may no longer be altered, amended or modified, even if the alteration, amendment
or modification is meant to correct what is perceived to be an erroneous conclusion of fact or law and
regardless of what court, be it the highest Court of the land, rendered it. In the past, however, we have
recognized exceptions to this rule by reversing judgments and recalling their entries in the interest of
substantial justice and where special and compelling reasons called for such actions. The matter before us
is of transcendental importance to the nation because of the subject matter involved agrarian reform

FACTS
• Apo Fruits Corporation (AFC) and Hijo Plantation, Inc. (HPI), together also referred to as
petitioners, were registered owners of vast tracks of land.
• they voluntarily offered to sell these landholdings to the government via Voluntary Offer to Sell
applications filed with the Department of Agrarian Reform (DAR).
• HPI and AFC rejected the valuations of Provincial Agrarian Reform Officer for being very low.
• the DAR requested the Land Bank of the Philippines (LBP) to deposit P26M in AFCs bank
account and P45M in HPIs bank account, which amounts the petitioners then withdrew. The titles
over AFC and HPIs properties were thereafter cancelled, and new ones were issued on December
9, 1996 in the name of the Republic of the Philippines.
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 • On February 14, 1997, AFC and HPI filed separate petitions for determination of just
compensation with the DAR Adjudication Board (DARAB). When the DARAB failed to act on
these petitions for more than three years, AFC and HPI filed separate complaints for
determination and payment of just compensation with the Regional Trial Court (RTC) of Tagum
City, acting as a Special Agrarian Court. These complaints were subsequently consolidated.
• On September 25, 2001, the RTC resolved the consolidated cases, fixing the just compensation
for the petitioners 1,338.6027 hectares of land1cra1aw at P1,383,179,000.00, with interest on this
amount at the prevailing market interest rates, computed from the taking of the properties on
December 9, 1996 until fully paid, minus the amounts the petitioners already received under the
initial valuation. The RTC also awarded attorneys fees.
• LBP moved for the reconsideration of the decision. The RTC, in its order of December 5, 2001,
modified its ruling and fixed the interest at the rate of 12% per annum from the time the
complaint was filed until finality of the decision. The Third Division of this Court, in its Decision
of February 6, 2007, affirmed this RTC decision.
• On motion for reconsideration, the Third Division issued its Resolution of December 19, 2007,
modifying its February 6, 2007 Decision by deleting the 12% interest due on the balance of the
awarded just compensation.
• All parties moved for the reconsideration of the modified ruling. The Court uniformly denied all
the motions in its April 30, 2008 Resolution. Entry of Judgment followed on May 16, 2008.
• AFC and HPI filed Second Motion for Reconsideration, with respect to the denial of the award of
legal interest and attorneys fees; Motion to Refer the Second Motion for Reconsideration to the
Honorable Court En Banc. GRANTED
• Court En Banc denied second MR
o the grant of the second motion for reconsideration runs counter to the immutability of
final decisions. Moreover, the Court saw no reason to recognize the case as an exception
to the immutability principle as the petitioners private claim for the payment of interest
does not qualify as either a substantial or transcendental matter or an issue of paramount
public interest.

ISSUE/S and HELD

RATIO
• As a rule, a final judgment may no longer be altered, amended or modified, even if the alteration,
amendment or modification is meant to correct what is perceived to be an erroneous conclusion
of fact or law and regardless of what court, be it the highest Court of the land, rendered it. In the
past, however, we have recognized exceptions to this rule by reversing judgments and recalling
their entries in the interest of substantial justice and where special and compelling reasons called
for such actions.
• final and executory judgment can no longer be attacked by any of the parties or be modified,
directly or indirectly, even by the highest court of the land
• However, this Court has relaxed this rule in order to serve substantial justice considering (a)
matters of life, liberty, honor or property, (b) the existence of special or compelling
circumstances, (c) the merits of the case, (d) a cause not entirely attributable to the fault or
negligence of the party favored by the suspension of the rules, (e) a lack of any showing that the
review sought is merely frivolous and dilatory, and (f) the other party will not be unjustly
prejudiced thereby.
• Invariably, rules of procedure should be viewed as mere tools designed to facilitate the attainment
of justice. Their strict and rigid application, which would result in technicalities that tend to
frustrate rather than promote substantial justice, must always be eschewed. Even the Rules of

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 Court reflects this principle. The power to suspend or even disregard rules can be so pervasive
and compelling as to alter even that which this Court itself had already declared to be final.
• That the issues posed by this case are of transcendental importance is not hard to discern from
these discussions. A constitutional limitation, guaranteed under no less than the all-important Bill
of Rights, is at stake in this case: how can compensation in an eminent domain be "just" when the
payment for the compensation for property already taken has been unreasonably delayed? To
claim, as the assailed Resolution does, that only private interest is involved in this case is to
forget that an expropriation involves the government as a necessary actor. It forgets, too, that
under eminent domain, the constitutional limits or standards apply to government who carries the
burden of showing that these standards have been met. Thus, to simply dismiss this case as a
private interest matter is an extremely shortsighted view that this Court should not leave
uncorrected.
• More than the stability of our jurisprudence, the matter before us is of transcendental importance
to the nation because of the subject matter involved agrarian reform, a societal objective that the
government has unceasingly sought to achieve in the past half century. This reform program and
its objectives would suffer a major setback if the government falters or is seen to be faltering,
wittingly or unwittingly, through lack of good faith in implementing the needed reforms. Truly,
agrarian reform is so important to the national agenda that the Solicitor General, no less,
pointedly linked agricultural lands, its ownership and abuse, to the idea of revolution.49cra1aw
This linkage, to our mind, remains valid even if the landowner, not the landless farmer, is at the
receiving end of the distortion of the agrarian reform program.
• Based on all these considerations, particularly the patently illegal and erroneous conclusion that
the petitioners are not entitled to 12% interest, we find that we are duty-bound to re-examine and
overturn the assailed Resolution. We shall completely and inexcusably be remiss in our duty as
defenders of justice if, given the chance to make the rectification, we shall let the opportunity
pass.
DISPOSTIVE PORTION
WHEREFORE, in view of the foregoing, the petition is hereby GRANTED.

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