FACTS:

The case involves a Petition for Review on Certiorari seeking to nullify and reverse the decision and resolution of the Court of Appeals (CA) in a case involving Romeo Morales and Kukan, Inc. The CA decision affirmed the orders of the Regional Trial Court (RTC) of Manila, declaring Kukan, Inc. and Kukan International Corporation as one entity and holding them liable for the judgment award in favor of Morales. The facts of the case include Morales winning a bidding for a contract with Kukan, Inc., and being shortchanged by the company. Morales filed a complaint against Kukan, Inc., and despite the company being declared in default, Morales was granted a judgment award.

After securing a writ of execution, Kukan International Corporation claimed ownership of the properties levied upon, alleging that it was a separate corporation from Kukan, Inc. Morales filed a motion to pierce the veil of corporate fiction, and after a series of orders and motions, the RTC declared Kukan, Inc. and Kukan International Corporation as one entity and held them jointly and severally liable to pay the judgment award. The CA affirmed this decision, which led to the present petition for review.

Kukan, Inc. was adjudged liable for a sum of money in a final and executory judgment by the trial court. The trial court then issued an order to execute the judgment against the property of KIC. KIC filed a petition for review, arguing that there was no legal basis for the court's order as it was not a party to the case, was never served a summons or copy of the complaint, and the order modified the trial court's final decision. The Court of Appeals denied KIC's motion for reconsideration. KIC raised several issues, including whether the trial court had jurisdiction over KIC and whether the court correctly applied the principle of piercing the veil of corporate fiction. The Supreme Court ruled in favor of KIC, stating that the trial court cannot execute a final and executory judgment against the property of KIC. The court held that a final and executory decision is immutable and unalterable, and the supervisory control of the court does not extend to altering or amending such a decision.

In this case, an RTC decision was rendered in favor of the plaintiff, ordering Kukan, Inc. to pay various amounts to the plaintiff, Morales. The decision directed Kukan, Inc. to pay the specified awards to Morales. However, Kukan, Inc. argued that the writ of execution went beyond the terms of the judgment and was therefore a nullity. Kukan, Inc. contended that a writ of execution must conform to the fallo of the judgment.

Another issue in the case was whether the trial court had obtained jurisdiction over Kukan, Inc. Kukan, Inc. argued that it was neither made a party nor served with summons in the civil case. The appellate court deemed Kukan, Inc. to have voluntarily submitted to the jurisdiction of the trial court due to its filing of several pleadings. However, Kukan, Inc. asserted that it was a separate entity from the defendant Kukan, Inc., and consistently resisted the trial court's jurisdiction over its person. The court examined the rule on voluntary appearance and the jurisdiction acquired by the court over parties in civil cases.

Kukan Industrial Corporation (KIC) filed a special appearance before the Regional Trial Court (RTC) to assert that it is separate and distinct from Kukan, Inc. Despite this assertion, KIC was brought into the jurisdiction issue and was asked to submit to the jurisdiction of the RTC. KIC argued that it did not waive its objection to the lack of jurisdiction, as it firmly maintained that it and Kukan, Inc. are different entities. KIC insisted on its separate identity and sought relief in accordance with that position.

ISSUES:

1. Whether the trial court can, after the judgment against Kukan, Inc. has attained finality, execute it against the property of Kukan International Corporation (KIC).

2. Whether the trial court acquired jurisdiction over KIC.

3. Whether the trial and appellate courts correctly applied the principle of piercing the veil of corporate fiction.

RULING:

1. Against Whom Can a Final and Executory Judgment Be Executed:

   The execution of a final judgment against KIC, a party not originally liable, constitutes an improper alteration of the original decision. Consequently, the trial court cannot execute such a judgment debt against the property of KIC.

2. Propriety of the RTC Assuming Jurisdiction Over KIC:

   The trial court did not acquire jurisdiction over KIC as it was neither impleaded as a party defendant nor served with summons in Civil Case No. 99-93173. KIC's pleadings challenging jurisdiction, filed through a special, not voluntary, appearance, did not constitute a waiver of jurisdictional objections.

3. Piercing the Veil of Corporate Fiction:

   The principle of piercing the corporate veil is properly applied to hold a corporation liable only during a full-blown trial with proper jurisdiction over the entity. Since KIC was not a party to the initial suit and the principle was invoked post-judgment by mere motion, its application here was improper. Moreover, the circumstances of the case did not justify piercing the veil as there was insufficient evidence to establish KIC as merely an alter ego or successor of Kukan, Inc.

PRINCIPLES:

• Finality and Immutability of Judgment: Once final, a judgment cannot be altered, and any deviation in its execution that confers new liabilities is null and void.

• Jurisdiction Over the Parties: Jurisdiction over the defendant is acquired through service of summons or voluntary submission to the court's authority, which must be unequivocal.

• Piercing the Veil of Corporate Fiction: This doctrine is applicable only when there's clear evidence of misuse of corporate personality to perpetrate fraud or injustice and must be raised in a full-blown trial where the court has acquired jurisdiction over the implicated entities. Overlapping stock ownership alone is insufficient to pierce the corporate veil.