In agrarian reform, is retention by landowners a constitutionally

guaranteed right? If in the affirmative, is it absolute?

Delfino vs. Anasao, G.R. No. 197486, Sept. 10, 2014 -RAM

Ruling: Yes, but with exceptions. The right of retention is a constitutionally

guaranteed right, which is subject to qualification by the legislature. It serves
to mitigate the effects of compulsory land acquisition by balancing the rights
of the landowner and the tenant and by implementing the doctrine that
social justice was not meant to perpetrate an injustice against the
landowner.
A decision that has acquired finality becomes immutable and unalterable,
and may no longer be modified in any respect, even if the modification is
meant to correct erroneous conclusions of fact or law, and whether it will be
made by the court that rendered it or by the highest court of the land. This
doctrine of finality and immutability of judgments is grounded on
fundamental considerations of public policy and sound practice to the effect
that, at the risk of occasional error, the judgments of the courts must
become final at some definite date set by law.
There are, however, exceptions to the general rule, namely: (1) the
correction of clerical errors; (2) the so-called nunc pro tuncentries which
cause no prejudice to any party; (3) void judgments; and (4) whenever
circumstances transpire after the finality of the decision rendering its
execution unjust and inequitable. The exception to the doctrine of
immutability of judgment has been applied in several cases in order to serve
substantial justice.