G.R. No. 167968 - Florentino vs. Rivera

The case originated from a complaint filed before the Regional Trial Court (RTC) by Mariano, Cynthia, and Adelfa Rivera (hereinafter “Riveras”) against Vicente Florentino (private respondent).
Florentino, acting as third-party plaintiff, filed a counterclaim against Teofila Mendoza and others (hereinafter “Mendozas”), seeking rescission, annulment, redemption, reconveyance, and damages.
The complaint was docketed as Civil Case No. 5761-M.

Declared the lease contract terminated.
Ordered Florentino to deliver possession of the leased premises to the Riveras, allowing him to remove all removable improvements at his own expense.
Directed Florentino to pay the Riveras an annual lease rental for 1982 and compensate for damage due to an alleged unrealized annual harvest of 100 cavans of palay from 1978 onwards.
Ordered payment of attorney’s fees to the Riveras and the Mendozas.
Dismissed counterclaims for lack of merit.

The RTC decision was affirmed by the Court of Appeals in CA-G.R. CV No. 15784 on March 29, 1996.
Florentino subsequently filed a petition for review on certiorari before the Supreme Court, which was denied in a Resolution dated February 9, 2000.
The Resolution became final and executory on June 1, 2000, as reflected in the Book of Entries of Judgments.

After the finality of the RTC decision, the Riveras filed a Motion for Execution before the RTC, which was granted on August 14, 2000.
Florentino then moved for a reconsideration on the grounds that the order was vague and contradicted the Court of Appeals’ pronouncement, specifically concerning the computation of damages for unrealized harvest.
On September 13, 2000, the RTC issued an order clarifying that the damages for the unrealized annual harvest should be computed at 16.5 cavans instead of 100, effectively altering paragraph (cc) of its dispositive portion.
A subsequent motion for reconsideration by the Riveras was denied on October 31, 2000.

The appellate court found that the trial court had gravely abused its discretion by amending the final and executory judgment.
It held that the amendment substantially reduced the damages awarded to the respondents by altering the computation from 100 cavans to 16.5 cavans annually.

The Court of Appeals denied the motion for reconsideration in its Resolution dated April 26, 2005.
Florentino filed a petition for review before the Supreme Court, contending that the appellate decision was in error.

Petitioner’s contention centered on the alleged ambiguity in the dispositive portion of the RTC’s decision and the appellate court’s interpretation:

Florentino argued that the trial court merely “clarified and quantified” the damages following a perceived vagueness in the trial court’s dispositive order.
He maintained that such clarification should be allowed because the ambiguity was purportedly reconcilable with the statements found in the body of the appellate decision.

The respondents maintained that the final judgment, once declared final and executory, is immutable, and that the dispositive portion controls over any apparently conflicting evidences in the body of the decision.

Whether the trial court was authorized to modify the dispositive portion of its final and executory judgment by reducing the amount of damages awarded (from 100 cavans to 16.5 cavans) on a motion for reconsideration.
Whether such a modification amounts to an abuse of judicial discretion considering the established rule that a judgment, once final and executory, is immutable and unalterable.
Whether the apparent ambiguity in the dispositive portion of the trial court’s decision justified the trial court’s clarification in consonance with the body of the appellate court’s decision.