Practice question
After finality, the judgment debtor fully satisfies the adjudged obligation, and the creditor acknowledges payment. The creditor nevertheless seeks a second collection of the identical obligation, arguing that any consideration of post-finality payment violates immutability. Which is correct?
- Immutability always requires payment twice
- The debtor must reopen the entire merits trial to show satisfaction
- The court may recognize the established post-finality satisfaction and prevent unjust duplicate execution without retrying the original merits
- The payment automatically invalidates every unrelated judgment
- The creditor may decide unilaterally that acknowledged payment never occurred
Legal references
- https://lawphil.net/judjuris/juri2025/feb2025/gr_253218_2025.html — DOST Officials and Personnel v. COA, G.R. No. 253218, February 4, 2025, main decision on immutability, clerical errors, nonprejudicial nunc pro tunc entries, void judgments and post-finality circumstances.
- https://lawphil.net/courts/rules/rc_1-71_civil.html — Rule 39, final-judgment enforcement and satisfaction framework, read with the recognized jurisprudential exceptions.
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