1.

Due Process

Arriola v. COA1, Supreme Court ruled that the disallowance made by

the COA was not sufficiently supported by evidence, as it was based on
undocumented claims. The documents that were used as basis of the COA
Decision were not shown to petitioners therein despite their repeated
demands to see them; they were denied access to the actual canvass sheets
or price quotations from accredited suppliers. Absent due process and
evidence to support COA’s disallowance, COA’s ruling on petitioners’
liability has no basis.

National Center for Mental Health Management v. COA2, likewise

ruled that price findings reflected in a report are not, in the absence of the
actual canvass sheets and/or price quotations from identified suppliers,
valid bases for outright disallowance of agency disbursements for
government projects.

2. Immutability of Final Judgments

In Session Delights Ice Cream and Fast Foods v. Court of Appeals 3,

the Court held that “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, renders it.4
Any attempt on the part of the responsible entities charged with the
execution of a final judgment to insert, change or add matters not clearly
contemplated in the dispositive portion violates the rule on immutability
of judgments.”

In Filipro, Inc. v. Permanent Savings & Loan Bank5, the Court held
that “Nothing is more settled in law than that once a judgment attains
finality it thereby becomes immutable and unalterable. It may no longer
be modified in any respect, even if the modification is meant to correct
what is perceived to be an erroneous conclusion of fact or law, and
regardless of whether the modification is attempted to be made by the

1 G.R. No. 90364, 30 September 1991.

2 G.R. No. 114864, December 6, 1996, 265 SCRA 390, 400.
3 G.R. No. 172149, February 8, 2010.

4 Equitable Bank Corp. v. Sadac, G.R. No. 164772, June 8, 2006, 490 SCRA 380, 417.

5 G.R. No. 142236, September 27, 2006.

 court rendering it or by the highest court of the land. Just as the losing
party has the right to file an appeal within the prescribed period, the
winning party also has the correlative right to enjoy the finality of the
resolution of his case.6”

In First United Constructors Corporation v. Court of Appeals7, the

Court held that “Public policy and sound practice demand that at the risk
of occasional errors, judgments of courts should become final and
irrevocable at some definite date fixed by law. This is better observed if the
court executing the judgment would refrain from creating further
controversy by effectively modifying and altering the dispositive portion of
the decision, thus further delaying the satisfaction of the judgment. No
matter how just the intention of the trial court, it cannot legally reverse
what has already been settled.8”

In Uy v. Commission on Audit9, the Court held that “our undeviating

jurisprudence is that final judgments may no longer be reviewed or in any
way modified directly or indirectly by a higher court, not even by the
Supreme Court, much less any other official, branch or department of
Government.10 Administrative decisions must end sometime as public
policy demands that finality be written on controversies.11”

6 Dapar v. Biascan, G.R. No. 141880, September 27, 2004., 439 SCRA 179, 199.
7 G.R. No. 171901, December 19, 2006.
8 Johnson & Johnson (Phil.), Inc. v. Court of Appeals, 330 Phil. 856 (1996.)
9 G.R. No. 130685, March 21, 2000.
10 Johnson & Johnson (Phils.) Inc. v. C.A., et al., 262 SCRA 298 (1996)
11 Canoreco, et al. v. Hon. Torres, et al., 286 SCRA 666, 681 (1998).