A Philippine Legal Article

I. Introduction

A Certification of Finality is a court-issued document stating that a judgment, order, resolution, or decision has become final and executory. In Philippine litigation, it is often required before a party may enforce a judgment, annotate a decree, execute a ruling, claim benefits, cancel or transfer titles, implement administrative consequences, or prove that no further ordinary remedy remains available.

The issuance of a Certification of Finality is not merely clerical in effect. It is tied to one of the most important concepts in procedural law: finality of judgment. Once a judgment becomes final and executory, it generally becomes immutable, unalterable, and enforceable, subject only to recognized exceptions.

The phrase “Certification of Finality Fees” refers to the legal fees charged by Philippine courts for issuing this certification. These fees are part of the broader system of legal fees, court fees, and charges governed principally by Rule 141 of the Rules of Court, relevant Supreme Court issuances, and internal court procedures.

II. What Is a Certification of Finality?

A Certification of Finality is a written certification, usually issued by the Branch Clerk of Court, Clerk of Court, or authorized court personnel, confirming that a judgment, order, or resolution has attained finality.

It commonly states that:

a specific decision, order, judgment, or resolution was rendered on a particular date;
the parties received notice of the decision or order;
the period to appeal, move for reconsideration, or seek further review has expired;
no appeal, motion, or petition was filed within the reglementary period, or any such remedy has already been resolved;
the judgment, order, or resolution has become final and executory as of a stated date.

The certificate is usually issued upon request of a party, counsel, government office, or interested person who needs official proof of finality.

III. Why Finality Matters in Philippine Procedure

Finality determines when a court ruling may be enforced and when the case is considered concluded for ordinary procedural purposes.

A judgment becomes final and executory when:

the period to appeal lapses without an appeal being perfected;
the period to file a motion for reconsideration or new trial lapses without such motion being filed;
a filed motion for reconsideration is denied and no further remedy is timely pursued;
an appellate court judgment becomes final after the lapse of the period for further review;
the Supreme Court issues an entry of judgment, where applicable.

The principle of immutability of judgments generally provides that once a judgment has become final and executory, it may no longer be modified, even if the modification is meant to correct an erroneous conclusion of fact or law. This rule exists to end litigation, protect vested rights, and preserve the stability of judicial decisions.

Recognized exceptions may include clerical errors, nunc pro tunc entries, void judgments, supervening events, or circumstances where execution would be unjust or impossible.

IV. Common Situations Where a Certification of Finality Is Needed

A Certification of Finality is commonly requested in:

1. Civil cases

Examples include collection cases, damages, specific performance, injunctions, ejectment appeals, annulment of contracts, partition, quieting of title, and declaratory relief.

It may be required before a party files a motion for execution, annotates a judgment on a land title, or presents the decision to a government agency.

2. Criminal cases

A certification may be needed to show that a conviction, acquittal, dismissal, or other order has become final. It may be relevant for release, probation, service of sentence, cancellation of bail, administrative reporting, or record-clearing purposes.

3. Family law cases

In annulment, declaration of nullity of marriage, legal separation, custody, support, adoption, guardianship, and similar proceedings, finality is often necessary before the court’s ruling may be registered or implemented.

For example, in marriage nullity or annulment cases, a certificate of finality may be required before the decision is annotated with the civil registrar or before related entries are processed.

4. Land registration and property cases

Registries of Deeds often require proof that a court order or decision affecting title has become final. This may apply to cancellation of title, issuance of new title, reconstitution, correction of technical descriptions, partition, foreclosure-related matters, or other property adjudications.

5. Probate, settlement, and special proceedings

Finality may be necessary before distributing estate assets, implementing orders of partition, approving final accounts, or closing proceedings.

6. Administrative or quasi-judicial matters elevated to courts

A party may need a certification to prove that a reviewing court’s decision has become final, especially where the decision affects employment, licensing, benefits, disciplinary liability, or government records.

V. The Legal Basis for Charging Fees

The authority to collect fees for certifications issued by courts comes from the rules on legal fees. In Philippine courts, these are principally found in Rule 141 of the Rules of Court, as amended by Supreme Court issuances.

Rule 141 covers filing fees, docket fees, sheriff’s fees, appeal fees, motion fees, commission fees, and various charges for certified copies, certifications, clearances, and other court services.

A Certification of Finality is generally treated as a form of court certification, and its issuance is subject to the corresponding legal fee under the applicable schedule.

The precise amount may vary depending on the current version of Rule 141, later Supreme Court circulars or administrative matters, the type of court, the number of pages or copies requested, whether certified true copies are also requested, and whether documentary stamp tax or other charges apply.

Because court fees are periodically amended, the safest legal formulation is this: the applicable Certification of Finality fee is the amount fixed by the current Rule 141 schedule and related Supreme Court issuances in force at the time of request.

VI. Certification of Finality Fee vs. Certified True Copy Fee

A Certification of Finality is often requested together with a certified true copy of the decision, order, or entry of judgment. These are related but distinct.

A Certification of Finality certifies the legal status of the ruling: that it has become final and executory.

A certified true copy certifies that a copy of a document is a faithful reproduction of the original or official court record.

Thus, a party may have to pay separate fees for:

the Certification of Finality;
certified true copies of the decision, order, or resolution;
photocopying or reproduction charges;
documentary stamp tax, where applicable;
mailing or transmission costs, if requested;
certification per page or per document, depending on the applicable schedule.

The fees are not necessarily bundled. A litigant should not assume that payment for a certified copy automatically includes the fee for a Certification of Finality.

VII. Who Issues the Certification?

The issuing office depends on the court and the stage of the case.

1. First-level courts

These include Metropolitan Trial Courts, Municipal Trial Courts in Cities, Municipal Trial Courts, and Municipal Circuit Trial Courts. The certification is usually issued by the Branch Clerk of Court or the Office of the Clerk of Court, depending on internal practice.

2. Regional Trial Courts

For cases decided by an RTC branch, the Certification of Finality is usually issued by the Branch Clerk of Court of the branch that rendered the decision or order.

3. Court of Appeals, Sandiganbayan, Court of Tax Appeals, and Supreme Court

In appellate courts, finality is usually reflected through an Entry of Judgment or a certification issued by the appropriate judicial records division, clerk of court, or division clerk, depending on the tribunal’s internal rules.

A litigant should distinguish between:

a Certification of Finality issued by a trial court; and
an Entry of Judgment issued by an appellate court.

Both may show finality, but they are not always procedurally identical.

VIII. When May a Certification of Finality Be Requested?

A Certification of Finality may be requested only after the judgment or order has actually become final.

The court personnel must usually verify:

the date the decision or order was promulgated or issued;
the date each party or counsel received notice;
the applicable reglementary period;
whether a motion for reconsideration, new trial, appeal, petition for review, notice of appeal, record on appeal, or other remedy was filed;
whether any higher court issued a temporary restraining order, writ, or order affecting finality;
whether there remains any unresolved incident that prevents finality.

If finality has not yet attached, the court should not issue the certification.

IX. Computing Finality

The computation depends on the remedy available and the applicable procedural rules.

Common periods include:

15 days from notice of judgment or final order for ordinary appeals in many civil and criminal cases;
30 days where a record on appeal is required;
special periods under the Rules of Summary Procedure, Small Claims Rules, environmental rules, family court rules, or special laws;
periods for petitions for review or appeals from quasi-judicial agencies;
periods in criminal cases, which may vary depending on the judgment and available remedy.

The reckoning point is usually notice to the party or counsel, not merely the date of promulgation or issuance.

If a party files a timely motion for reconsideration or new trial, finality is interrupted. The period may resume or a fresh period may apply, depending on the procedural rule and jurisprudential doctrine applicable to the case.

The court must be careful in issuing certifications because an erroneous certification of finality can cause improper execution, premature enforcement, or prejudice to appellate rights.

X. Who May Request a Certification of Finality?

Usually, the following may request it:

a party to the case;
counsel of record;
an authorized representative of a party;
a government agency requiring the document;
an interested person who can show legitimate purpose;
heirs, successors, or assigns, where appropriate.

Courts may require authorization, identification, or proof of interest, especially in sensitive matters such as family cases, adoption, guardianship, violence against women and children cases, child-related proceedings, sealed records, or criminal matters involving confidentiality.

XI. Documents Commonly Required

Requirements vary by court, but a requesting party may be asked to provide:

written request or letter-request;
case title and docket number;
copy of the decision, order, or resolution;
proof of authority, if filed by a representative;
valid identification;
official receipt showing payment of legal fees;
documentary stamps, where required;
return envelope or mailing details, if remote processing is allowed;
proof that no appeal or motion remains pending, if necessary.

Some courts may have request forms. Others accept a simple written request addressed to the Branch Clerk of Court or Clerk of Court.

XII. How Certification Fees Are Paid

Payment is usually made to the Office of the Clerk of Court or the designated collecting officer. The payer should receive an official receipt.

The process typically follows this sequence:

party files or submits a request;
court staff assesses the applicable fee;
party pays the assessed amount;
official receipt is issued;
branch verifies finality from the records;
certification is prepared;
authorized court officer signs and releases the certification.

A certification should generally not be released without payment of the required legal fees unless the requesting party is exempt by law, rule, or court order.

XIII. Fee Exemptions and Indigent Litigants

Not all parties are required to pay court fees in the same manner.

Possible exemptions may apply to:

indigent litigants allowed to litigate as paupers;
government agencies exempt under law or rule;
public prosecutors or government counsel requesting documents for official use;
parties covered by specific statutes granting exemption;
cases where the court authorizes deferred payment or exemption.

However, exemption from docket fees does not always automatically mean exemption from every incidental fee. The scope of the exemption depends on the law, rule, or order granting it.

An indigent party may need to file a motion or present proof of indigency unless already recognized by the court as an indigent litigant.

XIV. Certification of Finality in Civil Cases

In civil cases, a Certification of Finality is most commonly used before execution.

Under ordinary procedure, a judgment may be executed as a matter of right upon finality. A party may then file a motion for execution, attaching or relying on proof that the judgment has become final and executory.

In some cases, execution may issue even before finality through discretionary execution or execution pending appeal, but that is exceptional and requires specific grounds. A Certification of Finality is generally not the basis for execution pending appeal because, by definition, the judgment has not yet become final.

Certification fees in civil cases therefore often arise after the case is over, when the prevailing party is preparing to enforce the judgment.

XV. Certification of Finality in Criminal Cases

In criminal cases, finality may affect the rights of both the accused and the State.

A judgment of conviction generally becomes final when:

the accused fails to appeal within the reglementary period;
the accused commences service of sentence;
the accused applies for probation, where applicable;
the accused waives the right to appeal;
the judgment has been affirmed on appeal and no further remedy remains.

A judgment of acquittal is generally immediately final as to the accused because of the constitutional protection against double jeopardy, although the prosecution may have limited extraordinary remedies in exceptional circumstances, such as grave abuse of discretion.

A Certification of Finality in criminal cases may be used for:

commitment or release;
probation processing;
cancellation or forfeiture of bond;
correction of criminal records;
compliance with administrative requirements;
execution of civil liability adjudged in the criminal case.

Fees may still apply unless the requesting party or office is exempt.

XVI. Certification of Finality in Family Cases

In family law cases, finality has special importance because many judgments must be registered or annotated with civil registry offices.

In cases involving declaration of nullity of marriage, annulment, or legal separation, parties commonly need:

certified true copy of the decision;
certificate of finality;
entry of judgment, where applicable;
certificate of registration or annotation from the civil registrar;
related documents from the Office of the Solicitor General or prosecutor, depending on the case type and procedure.

The Certification of Finality is often required before the Local Civil Registrar or Philippine Statistics Authority records can be updated.

Because family cases may involve confidential records, courts may be stricter about who can request copies and certifications.

XVII. Certification of Finality in Land and Property Matters

Registries of Deeds often require proof of finality before implementing a court order that affects registered land. This protects the Torrens system from premature or reversible changes.

A Certification of Finality may be required for:

cancellation of title;
issuance of new title;
annotation or cancellation of liens;
judicial reconstitution;
correction of entries;
partition and adjudication;
foreclosure-related orders;
consolidation of ownership;
registration of court-approved compromise agreements affecting land.

In property cases, the Certification of Finality is often submitted together with certified true copies of the decision, order, writ, or other implementing documents.

XVIII. Certification of Finality vs. Entry of Judgment

A Certification of Finality and an Entry of Judgment both relate to finality, but they are different.

A Certification of Finality is a certification issued by the court stating that a ruling has become final and executory.

An Entry of Judgment is a formal entry in the book of entries of judgments, commonly associated with appellate courts, indicating that the judgment has become final.

In appellate practice, the Entry of Judgment is often the more formal document proving finality of an appellate decision. In trial court practice, the Certification of Finality is more commonly requested.

A party may need one or both depending on the receiving agency’s requirements.

XIX. Certification of Finality vs. Writ of Execution

A Certification of Finality is not the same as a writ of execution.

A Certification of Finality proves that the judgment is final.

A writ of execution commands the sheriff or proper officer to enforce the judgment.

The usual sequence is:

decision or order is issued;
parties receive notice;
appeal period lapses or remedies are resolved;
judgment becomes final;
certification or entry of judgment is obtained;
prevailing party moves for execution;
court issues writ of execution;
sheriff enforces the writ.

The certification itself does not execute the judgment. It supports the request for execution.

XX. The Nature of Certification Fees

Certification fees are generally ministerial legal charges imposed for the issuance of an official court document. They are not penalties, damages, or attorney’s fees.

They serve several purposes:

to defray administrative costs;
to regulate official issuance of court documents;
to maintain accountability through official receipts;
to support the judiciary’s legal fee system;
to prevent unauthorized or informal certifications.

The court employee should not collect amounts beyond those authorized by the rules. Payment should be covered by an official receipt.

XXI. Practical Components of the Amount Payable

The amount payable for securing a Certification of Finality may include several components:

1. Certification fee

This is the direct fee for issuance of the certification.

2. Certified copy fee

If the party requests certified true copies of the decision, order, or resolution, a separate charge may apply.

3. Copying or reproduction fee

Photocopying or printing charges may apply depending on court practice and available services.

4. Documentary stamp tax

Certain certificates or certified documents may require documentary stamps.

5. Research or retrieval fee

In older archived cases, additional retrieval or archive-related procedures may apply, depending on court practice and applicable rules.

6. Mailing or courier fee

If documents are requested remotely or sent by mail, transmission expenses may be charged separately.

XXII. Where the Money Goes

Court legal fees are public funds. They are collected through official channels and receipted accordingly.

Depending on the type of fee and applicable rules, court collections may be allocated to judiciary funds or government funds as prescribed by Supreme Court rules and fiscal regulations.

A party should always ask for and keep the official receipt, because it may be required for release of the certification and for later proof of payment.

XXIII. Problems That Commonly Arise

1. Premature request

A party sometimes requests a Certification of Finality before the appeal period has expired. The court should deny or hold the request until finality is confirmed.

2. Pending motion

A motion for reconsideration, new trial, clarification, or other incident may prevent finality.

3. Unclear date of receipt

Finality depends on notice. If the records do not clearly show when a party received the ruling, the court may be unable to certify finality.

4. Appeal filed in another court

A branch may hesitate to issue a certification if there is uncertainty whether an appeal or petition was filed with a higher court.

5. Multiple parties

If there are multiple parties who received the decision on different dates, finality may not be uniform as to all parties.

6. Partial finality

Some rulings may be final as to certain parties or issues but not as to others. The certification must be carefully worded.

7. Confidential records

In sensitive cases, the court may restrict access or require special authority.

8. Wrong office

A party may request a trial court certification when the final ruling was issued by an appellate court, or vice versa.

9. Nonpayment or underpayment

The certification may not be released unless the correct legal fees are paid.

10. Informal certifications

A verbal assurance from court staff is not a substitute for an official written certification.

XXIV. Can a Court Refuse to Issue a Certification of Finality?

Yes, if finality cannot be established or if procedural requirements are not met.

A court may refuse, defer, or require clarification where:

the period to appeal has not yet expired;
a motion or appeal is pending;
proof of receipt is incomplete;
the requesting person lacks authority;
the records are unavailable or archived;
the request concerns confidential records;
fees have not been paid;
there is a court order restricting release;
the request is directed to the wrong court.

However, once finality is clear, the proper party has authority, and the required fees are paid, issuance is generally ministerial.

XXV. Can a Certification of Finality Be Cancelled or Corrected?

A Certification of Finality may be corrected if it contains clerical errors or if it was issued by mistake.

Examples:

wrong case number;
wrong party name;
wrong date of decision;
wrong date of finality;
omission of relevant details;
certification issued despite a timely appeal or pending motion.

If the certification was wrongly issued, the court may issue a corrected certification or recall the erroneous one. The more difficult question is whether acts already done in reliance on the erroneous certification remain valid. That depends on the circumstances, good faith, notice, and the nature of the act performed.

XXVI. Remedies if the Court Will Not Issue the Certification

A party who believes that the court is improperly refusing to issue a Certification of Finality may consider:

filing a written request stating the basis for finality;
attaching proof of receipt and lapse of periods;
filing a motion to declare the judgment final and executory;
asking the court to direct the clerk to issue the certification;
seeking clarification from the appellate court if appellate proceedings are involved;
using appropriate remedies if refusal amounts to grave abuse of discretion or neglect of duty.

The proper remedy depends on whether the issue is administrative, clerical, or judicial.

XXVII. Certification Fees and Access to Justice

Certification fees are relatively small compared with docket fees, but they can still matter to indigent litigants. In cases involving family status, employment, benefits, release from detention, or land title, inability to secure a certification may delay meaningful enforcement of rights.

Philippine courts therefore balance two considerations:

the need to collect lawful court fees; and
the need to avoid denying access to justice because of poverty.

Rules on indigent litigants, pauper litigants, government exemptions, and court discretion exist to address this concern.

XXVIII. Certification of Finality in Small Claims

Small claims cases are designed for speed, simplicity, and finality. Judgments in small claims proceedings are generally final, executory, and unappealable, subject only to limited extraordinary remedies.

Because of this, a Certification of Finality in a small claims case may be requested soon after judgment, subject to the court’s verification and applicable fees.

A prevailing party may need the certification for execution or collection purposes.

XXIX. Certification of Finality in Ejectment Cases

In ejectment cases, timing is especially important because execution may proceed under specific procedural rules. A Certification of Finality may be necessary where the judgment has become final after appeal periods have lapsed or appellate remedies have been exhausted.

However, ejectment judgments also have special rules on immediate execution under certain circumstances. Therefore, finality and execution must be analyzed under the applicable rule governing forcible entry and unlawful detainer.

XXX. Certification of Finality in Appeals

Where a case has gone on appeal, the trial court should not issue a certification of finality of its own judgment if appellate proceedings have altered, superseded, or stayed the judgment.

Once an appellate court renders judgment, the relevant proof of finality may come from the appellate court, often through an entry of judgment.

After the appellate judgment becomes final, the records may be remanded to the lower court for execution or further proceedings. The party may then use the appellate entry of judgment and related certifications in the trial court.

XXXI. Certification of Finality and Electronic Courts

Philippine courts have increasingly used electronic filing, electronic notices, and digital case management systems. This affects finality because notice may be served electronically in some proceedings.

Where electronic service is valid, the date and time of electronic notice may affect computation of finality. The court must verify the applicable rules on electronic service, the date of receipt or constructive receipt, and whether the period to appeal or seek reconsideration has lapsed.

Certification fees may still be assessed even if the request or release is partly electronic, unless the rules provide otherwise.

XXXII. Best Practices for Requesting a Certification of Finality

A well-prepared request should include:

full case title;
docket number;
branch number and court location;
date of decision or order;
specific document sought to be certified final;
purpose of request;
name and authority of requester;
contact information;
attached copy of the decision or order, if available;
proof of payment once assessed.

A sample request may be framed as follows:

The undersigned respectfully requests the issuance of a Certification of Finality relative to the Decision dated ___ in Civil Case No. ___, entitled ___. The certification is needed for ___. The undersigned is the plaintiff/defendant/counsel/authorized representative in the case. The applicable legal fees shall be paid upon assessment.

XXXIII. Ethical and Administrative Considerations

Court personnel must issue certifications only through official processes. They should not demand unofficial payments, expedite in exchange for favors, or release documents without proper assessment and receipt.

Lawyers and litigants should likewise avoid informal arrangements. Certification fees are official legal fees, not facilitation payments.

If improper collection occurs, remedies may include reporting to the Executive Judge, Office of the Clerk of Court, Office of the Court Administrator, or other appropriate disciplinary authority.

XXXIV. Evidentiary Value of a Certification of Finality

A Certification of Finality is an official court document. It is generally entitled to respect because it is issued by the court custodian or authorized officer based on court records.

It may be used to prove:

finality of a decision;
enforceability of a judgment;
lapse of appeal period;
absence of pending ordinary remedies;
basis for execution or registration.

However, it is not conclusive if shown to be erroneous, fraudulently obtained, or issued without basis. Courts retain authority to correct their records.

XXXV. Effect of Nonpayment of Certification Fees

Nonpayment generally prevents issuance or release of the certification. The court may assess the request but withhold action until payment is made.

If a certification is issued without payment due to clerical mistake, the court may still require payment later, depending on the circumstances.

Nonpayment of certification fees is different from nonpayment of docket fees. Docket fees affect commencement of actions and jurisdictional concerns in certain contexts. Certification fees usually concern access to a court-issued document after a case event has occurred.

XXXVI. Relationship to Execution Fees and Sheriff’s Fees

Certification fees should not be confused with execution-related fees.

A party enforcing a judgment may have to pay:

fee for Certification of Finality;
fee for certified true copies;
motion fee for motion for execution, where applicable;
sheriff’s fees;
expenses for levy, garnishment, posting, publication, storage, or sale;
commission on amounts collected or realized, where applicable.

The Certification of Finality is only one part of the cost of enforcing a judgment.

XXXVII. Practical Examples

Example 1: Civil collection case

A plaintiff wins a collection case. The defendant receives the decision and does not appeal within the period allowed. The plaintiff requests a Certification of Finality, pays the assessed certification fee, obtains the certificate, and files a motion for execution.

Example 2: Annulment case

A decision declaring a marriage void becomes final. The petitioner obtains a Certificate of Finality and certified copies of the decision for registration with the civil registrar and annotation of civil status records.

Example 3: Land title correction

An RTC grants a petition correcting a title entry. The Registry of Deeds requires a certified true copy of the order and Certification of Finality before implementing the correction.

Example 4: Criminal conviction

An accused is convicted and does not appeal. The court issues a Certification of Finality for purposes of commitment, service of sentence, or related post-judgment proceedings.

Example 5: Appellate decision

The Court of Appeals affirms the RTC. After the period to elevate the case to the Supreme Court lapses, an entry of judgment is issued. The prevailing party uses the entry of judgment to seek execution in the trial court.

XXXVIII. Drafting Issues in the Certification

A good Certification of Finality should identify:

the court;
branch or division;
case title;
docket number;
date and nature of the decision, order, or resolution;
date of receipt by parties or counsel, where relevant;
statement that no appeal or motion was filed within the reglementary period, or that remedies have been resolved;
exact date of finality;
name, position, and signature of issuing officer;
court seal, where required;
official receipt reference, where relevant.

Precision is important. A vague certification may be rejected by agencies or challenged by adverse parties.

XXXIX. Common Misconceptions

1. “A decision is final on the date it is issued.”

Not necessarily. Finality usually depends on notice and lapse of the applicable period.

2. “A Certification of Finality automatically gives possession or payment.”

No. It proves finality but does not itself enforce the judgment.

3. “A certified true copy is the same as a Certification of Finality.”

No. They certify different things.

4. “Only lawyers can request it.”

Not always. Parties and authorized representatives may request it, subject to court requirements.

5. “The fee is optional.”

No. It is an official legal fee unless an exemption applies.

6. “Once issued, it can never be questioned.”

Incorrect. An erroneous certification may be corrected or challenged.

XL. Policy Reasons Behind Certification Fees

Certification fees reflect the judiciary’s need to regulate access to official court documents while maintaining record integrity. The fee is not meant to sell justice but to support administrative processing and accountability.

At the same time, fees must not become barriers to enforcement of rights. This is why exemptions, indigency rules, and official assessment procedures are important.

XLI. Key Takeaways

A Certification of Finality is an official court document confirming that a judgment, order, decision, or resolution has become final and executory.

The corresponding Certification of Finality fee is a legal fee charged under the court’s schedule of fees, principally governed by Rule 141 of the Rules of Court and related Supreme Court issuances.

The certification is commonly needed for execution, registration, annotation, release, implementation, and proof of finality before courts, government agencies, registries, and private institutions.

It is distinct from a certified true copy, an entry of judgment, and a writ of execution.

The exact fee depends on the current legal fee schedule, court type, number of documents, accompanying certified copies, documentary stamps, and possible exemptions.

The requesting party should file a proper request, pay the assessed fee through official channels, secure an official receipt, and ensure that the certification accurately identifies the judgment and the date of finality.