Facts:

• The case "Henderson v. Tan" involves the National Rubber Goods Manufacturing Company, Inc., a Philippine corporation with a capital stock of P1,000,000.
• James McI. Henderson, the Philippine Alien Property Administrator, took title to 4,619 shares of the company, which were Japanese-owned, under Vesting Order No. P-62 issued on March 20, 1947.
• This acquisition made Henderson the owner of 72% of the subscribed capital stock, thereby assuming management and control of the company.
• On June 24, 1947, Joseph Arcache claimed to be a mortgage creditor of the company for P70,000 based on a deed of mortgage dated September 24, 1942, and filed an action for foreclosure in the Court of First Instance of Rizal.
• The company was declared in default due to lack of personal notice and failure to file an answer, leading to a judgment on October 2, 1947, in favor of Arcache.
• The judgment included a moratorium clause suspending execution until 90 days after the lifting of an executive order on moratorium.
• The Philippine Alien Property Administrator did not contest the judgment, which became final.
• On March 15, 1949, Arcache filed a motion to lift the moratorium clause without notifying the company or the Administrator, citing reasons such as waiver of the defense of moratorium and delinquent taxes.
• The court granted the motion on May 9, 1949, leading to the auction and sale of the mortgaged properties to Arcache.
• The Administrator only learned of these proceedings on July 6, 1949, and subsequently filed a petition to declare the order and sale void, which was denied, prompting a petition for certiorari to the Supreme Court.

Issue:

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Ruling:

1. No, a court cannot amend a final judgment by removing a moratorium clause through an interlocutory order.
   • Key Point: Final judgments are not subject to amendment by interlocutory orders.
2. Yes, the lower court exceeded its jurisdiction by lifting the moratorium clause and authorizing the sale of the mortgaged properties....(Unlock)

Ratio:

• The Supreme Court emphasized that a final judgment cannot be amended except for clerical errors or misprisions unless control over it has been retained in some proper manner or a statute provides otherwise.
  • Key Principle: Judicial errors must be corrected through due process, not by altering...continue reading