G.R. No. 202860 - ARROYO V. CA
G.R. No. 202860 - ARROYO V. CA
G.R. No. 202860 - ARROYO V. CA
Doctrine: 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.46 The Court applies these exceptions in
order to serve the interests of justice.47
Facts:
This case arose from the enactment of Republic Act (R.A.) No. 8371, otherwise known as "The
Indigenous Peoples' Rights Act of 1997,"5 which resulted in the reorganization of two (2) offices:
(1) the Office for Northern Cultural Communities (ONCC);6 and (2) the Office of Southern
Cultural Communities (OSCC).7 Pursuant to the passage of R.A. No. 8371, the ONCC and
OSCC were merged as the organic offices of the National Commission on Indigenous Peoples
(NCIP).
Upon the effectivity of R.A. No. 8371, the positions of Staff Directors, Bureau Directors, Deputy
Executive Directors and Executive Directors, except the positions of Regional Directors and
below, were phased-out.10 Absorbed personnel were nonetheless subject to the qualifications set
by the Civil Service Commission and the Placement Committee.
Brito, who was then the Regional Director for Region V of the OSCC, was temporarily
appointed to the same position pursuant to the NCIP Executive Director's Memorandum Order
No. 01-98 dated May 23, 1998.12
On August 31, 2000, a list of appointees to the positions of Regional Directors and Bureau
Directors of the NCIP was transmitted to the NCIP Executive Director. Among them was
Arroyo, who was appointed as the Regional Director of Region V.13
Unsatisfied with the appointment of Arroyo and three (3) other appointees,14 Brito, together with
several other individuals formerly holding the positions of Bureau Director and Regional
Director,15 initiated a petition for quo warranto to challenge their appointment before the
CA.16 Brito invoked his right to security of tenure under R.A. No. 6656,17 and argued that Arroyo
does not possess the required Career Executive Service (CBS) eligibility for the position of
Regional Director.18
Arroyo accordingly refuted these arguments in her comment to the petition for quo
warranto.19 She argued that Brito cannot invoke the right to security of tenure because his
appointment was made in a temporary capacity.20 Arroyo also questioned the standing of Brito to
initiate the quo warranto petition, and argued that Brito was not qualified to be a Regional
Director of the NCIP.21
In a Decision22 dated August 30, 2004, the CA partially granted the petition for quo
warranto stating that [Batay-an] and [Brito] are hereby reinstated to their former positions as
Regional Director.
On September 24, 2004, Arroyo moved for the reconsideration of this decision by arguing that
the CESO Rank III eligibility of Brito is void for falsification of Brito’s bachelor’s degree.
Arroyo even cited newly discovered evidence supporting her claim that Brito did not obtain a
bachelor's degree, which is an academic qualification for the position of Regional Director.
However, the CA remained unmoved by these arguments. Arroyo's motion for reconsideration
was denied in the Resolution.
Following the resolution of the motion for reconsideration, Arroyo did not elevate the matter to
this Court for review.32 This prompted Brito to file a Motion for Entry of Judgment and for the
Issuance of a Writ of Execution dated March 26, 2007, praying for the CA to execute the
judgment granting his quo warranto petition.33
On May 3, 2007, 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 in O.P. Case No. 05-F-175,
which dismissed Brito from government service for falsifying his college academic records. This
OP decision allegedly became final and executory because Brito failed to appeal to the CA.34
Brito, on the other hand, countered that the OP decision dismissing him from service was not yet
final and executory. He posited that there is an existing appeal from the OP decision, lodged
before the CA.35
Ruling of the CA
The CA found that the Decision dated August 30, 2004 of the CA, granting the quo
warranto petition of Brito against Arroyo, had become final and executory, thus warranting the
enforcement of the decision.
Consequently, Arroyo filed a Motion for Reconsideration dated December 29, 2010.38 Arroyo
insisted that Brito was dismissed from government service and disqualified from holding
government office.
The CA found Arroyo's argument unmeritorious and denied her motion for reconsideration.
Aggrieved, Arroyo filed the present petition for certiorari assailing the Resolutions dated
December 7, 2010 and June 8, 2012 of the CA for having been issued with grave abuse of
discretion amounting to lack or excess of jurisdiction. Arroyo insists that Brito is not qualified to
hold the position of Regional Director because he falsified his bachelor's degree from NCF.
Issue: Whether the CA gravely abused its discretion, amounting to lack or excess of jurisdiction,
in directing the execution of its Decision dated August 30, 2004 granting the quo
warranto petition of Brito.
Courts may modify a final and executory decision when circumstances transpire that render
the execution unjust or inequitable.
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.44 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.45
In this case, Arroyo invoked the last exception, which relates to supervening events. According
to Arroyo, the OP's Decision dated December 15, 2005 in O.P. Case No. 05-F-175, which found
Brito liable for dishonesty because he falsified his college degree, changed the situation of the
parties in such a manner that renders the execution of the quo warranto judgment unjust and
inequitable.48 Thus, in granting the enforcement of the quo warranto decision, she argues that the
CA gravely abused its discretion, amounting to lack or excess of jurisdiction.49
A supervening event, in order to apply, must rest on proven or certain facts.50 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.51 It should directly affect the matter already
litigated and settled, or substantially change the rights or relations of the parties.52
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,53 and Brito has
commenced the execution of the quo warranto decision in his favor.54 Verily, the supervening
event referred to in the present case transpired after the finality of the judgment that Brito sought
to execute.