The short concept: “finality” first, then “entry”

In Philippine appellate practice, entry of judgment is not the moment the Court of Appeals (CA) decides a case. It happens after the decision (or final resolution) becomes final and executory—meaning the law gives the losing party time to seek reconsideration or elevate the case to the Supreme Court (SC), and that time expires (or the remedies are exhausted).

So the timing is best understood in two steps:

Finality (final and executory): the decision can no longer be changed through the usual remedies.
Entry of judgment: the CA clerk makes the formal entry in the Book of Entries of Judgments and typically issues an Entry of Judgment / Certificate of Finality, then the case is usually set for remand (return of records) to the lower court/tribunal for execution or further proceedings.

The governing framework is found in the Rules of Court on appellate judgments and entries of judgment, together with rules on motions for reconsideration and petitions for review to the Supreme Court.

Key terms you must not mix up

1) Decision vs. Resolution

Decision: the CA’s ruling on the merits.
Resolution: usually resolves motions (like a motion for reconsideration) or procedural matters; a resolution denying a motion for reconsideration can be the “final resolution” that triggers the last period to go to the SC.

2) Finality vs. Entry of Judgment

Finality is a legal status: the judgment is already final and executory.
Entry of judgment is a formal, clerical act: the clerk records that final judgment in the book and issues proof of finality.

A judgment can be final and executory even if the physical “entry” document is issued slightly later due to processing.

3) Notice and counting of days

Most deadlines run from receipt of notice of the CA decision/resolution, not from the date printed on it. Counting is governed by procedural rules on computation of time (e.g., excluding the day of receipt; handling weekends/holidays based on the applicable procedural rules in force).

General rule: when does the CA enter judgment?

The CA generally enters judgment after the period to seek reconsideration or to elevate the case has lapsed without a timely filing, or after such remedies are resolved and no further timely remedy is taken.

In practical terms, the earliest possible entry of judgment is usually after the initial 15-day period, but the true date depends on what the parties do (or don’t do).

The most common timelines (civil cases)

Scenario A: No motion for reconsideration (MR), no Supreme Court petition

Day 0: You receive the CA decision. Within 15 days: losing party may file an MR in the CA (typical) and/or prepare to go to the SC (depending on the proper remedy). After day 15 (if nothing is filed): the CA decision becomes final and executory. After finality: the CA clerk makes the entry of judgment and issues the Entry of Judgment/Certificate of Finality.

Bottom line: Earliest finality is usually 15 days from notice, with entry following shortly after.

Scenario B: MR is filed and denied; no Supreme Court petition is filed after denial

Day 0: you receive the CA decision. By Day 15: MR is filed (timely). This generally prevents finality while the MR is pending. Later: CA issues a resolution denying the MR; you receive notice of that denial. From receipt of denial: a period typically runs to elevate the matter to the SC (often 15 days, depending on the remedy). If no SC petition is filed within that period: the CA decision becomes final and executory, then entry of judgment follows.

Bottom line: finality is pushed back—first by the time it takes the CA to resolve the MR, then by the last period to go to the SC.

Scenario C: MR is denied; a petition is filed in the Supreme Court

Once a timely and proper petition is filed in the SC (commonly a petition for review on certiorari), the CA judgment is not yet “done” in the sense of being unalterable because the case is now under potential SC review.

If the SC denies the petition and that denial becomes final, then the CA ruling effectively stands, and execution proceeds consistent with the final outcome.
The details of when and where entry of judgment is recorded can depend on the posture: the SC will enter judgment on its action, and the CA’s action may already be treated as final as affirmed/left standing, with remand directions flowing from the SC’s final action.

Bottom line: a timely SC petition typically delays the “end of the road” beyond the CA level.

Criminal cases: similar structure, different consequences

In criminal cases, the same “finality then entry” logic applies, but the consequences are more immediate (commitment, release, execution of penalties, etc.). The accused/prosecution may have different available remedies depending on what the CA did (affirmed conviction, modified penalty, acquittal, etc.). As a rule, entry of judgment still follows finality, and finality is still affected by timely MR and timely SC recourse.

What filings stop the clock—and what do not?

Filings that usually prevent finality (timely and proper)

Motion for reconsideration (MR) in the CA filed within the allowed period.
Proper and timely recourse to the Supreme Court (commonly Rule 45 petition for review on certiorari in many CA decisions), filed within the period counted from notice of judgment or denial of MR (as applicable).

Filings that often do not stop finality (depending on context)

Motions that are pro forma (filed without complying with essential requirements) are typically treated as not tolling deadlines.
Late filings generally do not toll.
Improper remedy (e.g., filing a remedy that is not allowed for that kind of CA disposition) can be fatal and may not prevent finality if dismissed as improper/late.

Practical point: Whether a filing actually stops finality depends on timeliness, form, substance, and the correct remedy.

The usual “base period” you’ll hear: 15 days—why it matters

For many CA dispositions, the everyday working timeline is built around 15 days from receipt:

15 days to move for reconsideration in the CA (common baseline).
After MR denial, another 15-day window is commonly relevant for elevating to the SC via the proper remedy (frequently Rule 45), subject to the Supreme Court’s rules on extensions and strict compliance.

This is why lawyers often speak in “15-day blocks,” but those blocks can be expanded by:

Time for the CA to resolve the MR (could be weeks to months).
Time consumed by SC proceedings if a petition is filed.
Administrative processing time for issuance of the Entry of Judgment.

“So exactly how long until entry of judgment?”

Here’s the cleanest way to think about it:

Minimum (best-case for quick entry)

About 15 days from receipt of the CA decision if nobody files anything, plus the CA’s internal processing time to actually issue the entry/certificate.

Common (when MR is filed)

15 days to file MR (used), then
time for the CA to resolve the MR, then
a further period after denial during which SC review may be sought, and only after that lapses does entry happen—again plus processing time.

Longest (when the case goes to the Supreme Court)

Entry at the CA level is effectively overtaken by the timeline of SC review; the practical “finality” that matters for execution often waits for the SC’s action to become final.

What actually happens after entry of judgment?

1) Issuance of proof of finality

Parties typically request or receive:

Entry of Judgment, and/or
Certificate of Finality (terminology varies in practice, but both serve to prove that the decision/resolution is final).

2) Remand of records

The CA typically:

Remands the records to the trial court/agency/tribunal of origin, with directions consistent with the final judgment.
The lower court then acts on execution (civil) or implementation (criminal), or conducts further proceedings if the CA ordered a remand for additional action.

3) Execution stage begins (civil)

Once final and executory, the prevailing party usually proceeds with:

Motion for execution (where required), writs, garnishment, levy, etc., depending on the judgment.

Common confusions that change the answer

Confusion 1: “The decision date is December 1, so entry is December 16.”

Not necessarily. Deadlines run from receipt of notice, not the decision date. If you received it later, the 15 days is counted from the later receipt.

Confusion 2: “If we filed MR, the decision can still be executed.”

Generally, a timely MR delays finality. Execution as a matter of right normally follows finality; “execution pending appeal” is a separate, exceptional track and depends on strict requirements and context.

Confusion 3: “Entry of judgment is automatic exactly on the 16th day.”

Entry is a ministerial act after finality, but it still involves clerical processing. Some entries are made promptly; some take longer due to workload, transmittal, and administrative steps.

Practical indicators that entry is near (or already happened)

You’ll usually see one or more of the following:

A CA issuance titled Entry of Judgment or Certificate of Finality.
A notice that records are remanded to the lower court.
A docket entry showing the judgment has become final and executory.

A lawyerly way to state the rule (Philippine context)

Entry of judgment in the Court of Appeals is made after the judgment or final resolution becomes final and executory—i.e., after the lapse of the period to file a motion for reconsideration or to seek Supreme Court review, or after those remedies are resolved and no further timely remedy is pursued.

Quick reference examples (based on receipt dates)

Example 1: No MR, no SC petition

Receive CA decision: January 10
Last day to file MR: January 25 (subject to rules on counting and non-working days)
Finality: after January 25
Entry of judgment: after finality, when processed

Example 2: MR filed; MR denied; no SC petition

Receive CA decision: January 10
MR filed: January 20
Receive denial of MR: March 5
Period to elevate to SC runs from March 5 receipt
If no SC petition: finality after that period, then entry follows

Bottom line

If no MR and no Supreme Court recourse is taken, entry of judgment is usually reachable soon after the 15-day period from notice. If an MR is filed, entry usually happens only after the MR is resolved and the last period to go to the Supreme Court lapses. If the case is elevated to the Supreme Court, the meaningful “end point” for execution often depends on the Supreme Court’s final action, not the CA’s initial decision date.