Immutability of Final Judgments

Upon finality of the judgment, the Court loses its jurisdiction to amend, modify or alter the same. Except for correction of clerical errors or the making of nunc pro tunc entries which cause no prejudice to any party, or where the judgment is void, the judgment can neither be amended nor altered after it has become final and executory. This is the principle of immutability of final judgment. (Bongcac v. Sandiganbayan, G.R. No. 156687-88, May 21, 2009)

It is true that notwithstanding the principle of immutability of final judgments, equity still accords some recourse to a party adversely affected by a final and executory judgment, specifically, the remedy of a petition to annul the judgment based on the ground of extrinsic fraud and lack of jurisdiction, or the remedy of a petition for relief from a final order or judgment under Rule 38 of the Rules of Court. He may also have a competent court stay the execution or prevent the enforcement of a final judgment when facts and circumstances that render execution inequitable or unjust meanwhile transpire; or when a change in the situation of the parties can warrant an injunctive relief (Angelina Pahila-Garrido Vs. Elisa M. Tortogo, et al., G.R. No. 156358. August 17, 2011).