How to Secure a Certificate of Finality in the Philippines

A practical guide for litigants, counsel, and court staff

What Is a Certificate of Finality?
Legal Bases
When Does a Judgment Become Final?
Entry of Judgment vs. Certificate of Finality
Why You May Need One
Who Issues It, and Who May Apply
Step-by-Step Procedures 7.1 Trial Courts (MTC/RTC) 7.2 Court of Appeals 7.3 Supreme Court 7.4 Quasi-Judicial Agencies
Documentary Requirements
Fees, Processing Times, and Follow-Up
Sample Forms
Common Pitfalls and Practical Tips
Frequently Asked Questions
Conclusion

1 What Is a Certificate of Finality?

A Certificate of Finality (CoF) is an official court certification attesting that a decision, resolution, or order has become final and executory because the reglementary period for review or appeal has lapsed without any further timely remedy filed (or after such remedy has been resolved with finality).

It is not the same as the judgment itself. It is a separate, ministerial document issued by the clerk of court or proper issuing officer confirming that no more appeal or reconsideration is legally available.

2 Legal Bases

Level	Governing Rule/Issuance	Key Provision
Trial Courts	Rule 36, Rules of Court	Sec. 2: “Entry shall be made when judgment becomes final, and the clerk shall forthwith issue a certified true copy of the judgment and its entry.”
Court of Appeals	Rule 51, Sec. 10	The clerk “shall issue a certified true copy of the judgment and its entry upon request.”
Supreme Court	Rule 56, Sec. 9 and SC Circulars	Clerk of Court of the SC issues an Entry of Judgment; upon application and payment, a CoF may be issued for submission to lower courts, agencies, or registries.
Quasi-Judicial Bodies	sector-specific charters (e.g., NLRC Rules, HLURB/ DHSUD Rules, LRA Circulars)	Each provides that decisions become final after a fixed period, after which a certificate or finality order may be issued.

3 When Does a Judgment Become Final?

Forum	Reglementary Period to Appeal / Move for Reconsideration	Notes
MTC/RTC (ordinary civil & criminal)	15 days from notice of judgment (criminal: 15 days from promulgation or notice to accused)	Extension not allowed, except Rule 42 petitions (CA) which may obtain a 15-day extension for compelling reason.
Family Courts (annulment, adoption, custody)	Same 15-day rule; some special laws fix different periods (e.g., RA 11222 simulated birth—10 days).
Court of Appeals	15 days from notice; one-time extension of 15 days (Rule 52, Sec. 1).
Supreme Court	15 days from receipt of decision/resolution; extensions are not “granted as a matter of right” and rarely exceed 30 days.
NLRC	10 calendar days from receipt (Labor Code, Art. 229).
HLURB / DHSUD	15 days from receipt of decision (RA 11201 IRR).
CTA (Division)	15 days to move for reconsideration or elevate to CTA En Banc (RA 1125).

Finality Date = Last day of the period (inclusive) if no allowable pleading is actually filed. If the period ends on a weekend or holiday, the deadline rolls over to the next working day (Rule 22).

4 Entry of Judgment vs. Certificate of Finality

Feature	Entry of Judgment (EJ)	Certificate of Finality (CoF)
What is recorded?	Clerk records the fact and date a judgment became final in the Book of Entries of Judgments.	A separate, certified document stating the decision is final and executory.
Issued automatically?	Yes (ministerial) after lapse of time.	No—usually upon party’s written request and payment of fees.
Purpose	Internal court record; basis for issuance of writs.	External evidence for other tribunals/registries (e.g., Registry of Deeds, PSA, SEC).
Contains	Case title, docket number, dispositive portion, date of finality, clerk’s signature.	Same data plus a statement: “No appeal, motion for reconsideration, or other pleading has been filed within the reglementary period.”
Typical recipients	Sheriff, lower courts	PSA, LRA, BIR, foreign courts, government agencies

5 Why You May Need One

Land Registration – annotate the CoF on the title for land registration cases (Rule 74, Rule 63, PD 1529).
Civil Status Changes – PSA requires CoF to register decrees of annulment, declaration of nullity, adoption, change of name, correction of entry (SC Adm. Matter 02-11-11-SC).
Execution of Judgment – sheriffs sometimes demand a CoF for large-value writs or ejectment.
Corporate Proceedings – SEC or cooperative agencies request it to dissolve or reorganize entities.
Foreign Enforcement – foreign courts often insist on proof of finality before recognizing a Philippine judgment.
Taxation – BIR assessments or refunds ordered by CTA must attach a CoF to close the docket.

6 Who Issues It, and Who May Apply

Issuing Office	Who May Apply
Office of the Clerk of Court (OCC) of the court that rendered the judgment	(a) counsel of record, (b) winning party, (c) losing party (if needed), (d) duly authorized representative with SPA.
Supreme Court–Judgments Division	same; often sought by CA or trial court clerks or by parties for registration.
Executive Clerks (CTA, Sandiganbayan)	counsel/parties.
Secretaries of quasi-judicial agencies	parties or counsel.

7 Step-by-Step Procedures

7.1 Trial Courts (MTC/RTC)

Confirm finality date: Check the notice of judgment and service return; count 15 days.
Draft a one-page Motion/Request for issuance of Certificate of Finality (some clerks accept a letter-request).
Attach: (a) proof of receipt of judgment (registry return card or sheriff’s return), (b) photocopy of decision.
Pay the fee at the Clerk of Court cashier (see OCA Circular 96-2023: ₱380 basic certification fee + ₱20 per page for copies).
Submit to Docket/Records Section. The clerk verifies docket, confirms no appeal or MR on file, issues CoF within 1–3 working days.
Receive the original CoF with dry seal; secure certified copies if needed.

7.2 Court of Appeals

Wait for the Entry of Judgment (usually prepared 7–10 days after finality).
File a Manifestation/Request citing Rule 51 Sec. 10, pay CA fees (roughly ₱500).
CoF issued by the Division Clerk; mailed or personally released.

7.3 Supreme Court

Track the SC docket (sc.judiciary.gov.ph or clerk’s hotline) and note the date of Entry of Judgment.
Prepare a verified request (form available at SC window) with photocopy of SC decision/resolution.
Pay fees (A.M. 04-2-04-SC, Item 7: ₱500 certification + ₱20/page copies).
Processing time: ~10–15 working days; follow up at Judgments Division; rush service is not officially allowed.

7.4 Quasi-Judicial Agencies

Procedure mirrors court practice; many bodies (e.g., NLRC) issue a “Certificate of Finality/Entry of Judgment” in one form. File a motion or letter, attach proof of receipt, pay fee (varies ₱100–₱300).

8 Documentary Requirements (Typical)

Request/Motion (indicating case title, docket number, decision date, date finality lapsed).
Proof of Service of judgment/resolution to all parties (registry return card, personal service receipt, or JBCS tracking printout).
Official Receipts of filing/payment.
Special Power of Attorney or board resolution if applicant is a representative.
Photocopy of decision and Entry of Judgment (to facilitate verification).
Valid ID of requesting party/representative.

9 Fees, Processing Times, and Follow-Up

Forum	Basic Certification Fee	Copy Fee	Usual Lead Time
MTC/RTC	₱380	₱20/page	1–3 working days
CA (Dec. 2024 rates)	₱500	₱20/page	3–7 working days
SC	₱500	₱20/page	10–15 working days
CTA / Sandigan	₱500	₱20/page	5–7 working days
NLRC	₱150	₱10/page	1–2 working days

Tip: Always bring extra cash and photocopies. Provincial stations may add mailing costs.

10 Sample Forms

(A) Motion to Issue Certificate of Finality – RTC

Republic of the Philippines
REGIONAL TRIAL COURT
Branch ___, _____ City

PEOPLE OF THE PHILIPPINES,          Criminal Case No. ___
   Plaintiff,                       (Violation of _____)
         – versus –
JUAN DELA CRUZ,                     Accused.

     x------------------------------------------x

                   MOTION FOR ISSUANCE OF
                   CERTIFICATE OF FINALITY

Accused JUAN DELA CRUZ, by counsel, respectfully states:

1.  The Judgment dated 12 March 2025 acquitting the accused was received by undersigned counsel on 17 March 2025.
2.  More than fifteen (15) days have elapsed and no appeal or motion for reconsideration has been filed by the prosecution, as evidenced by the docket entries.
3.  The decision has therefore become final and executory on 2 April 2025.

WHEREFORE, premises considered, it is respectfully prayed that the Honorable Court, through the Office of the Clerk of Court, issue a Certificate of Finality.

____ City, Philippines, 4 April 2025.

                               (sgd.) Atty. Maria Santos
                               Counsel for Accused
                               PTR No. ___ / IBP No. ___
                               Roll No. ___

(B) Letter-Request – Land Registration Case (LRA)

Clerk of Court
RTC Branch 75, Legazpi City

Sir/Madam:

Kindly issue a Certificate of Finality for the Decision dated 15 January 2025 (LRC Case No. 12345) titled “In Re: Petition for Issuance of Title (Sec. 14, PD 1529)–Spouses Reyes.” The decision became final on 31 January 2025, there being no appeal filed.

Attached are copies of (1) decision, (2) proof of service, and (3) official receipt.

Thank you.

Very truly yours,
(sgd.) ATTY. REYNALDO LIM
Counsel for Petitioners

11 Common Pitfalls and Practical Tips

Pitfall	How to Avoid
Wrong counting of days (holidays/non-working days).	Use the Judiciary Plan of Holidays; if in doubt, ask the clerk.
Premature filing (before lapse period).	File on the 16th day (or 11th for NLRC); late filing is harmless but early filing causes denial.
Incomplete proof of service.	Secure all registry receipts and post-office certifications; subpoena returns if personally served.
Misnaming the document (e.g., asking for “Entry of Judgment” when you need a CoF).	Specify both if required: request “Entry of Judgment and Certificate of Finality.”
Expired SPA or ID of representative.	Present IDs valid for at least six months; notarize SPA within 90 days.
Non-payment of copy fees.	Bring small bills and coins; some OCCs require exact change.
Expecting the court to mail it quickly.	Arrange for personal pick-up or attach a prepaid courier pouch.

12 Frequently Asked Questions

Q 1. Is a Certificate of Finality automatically issued?

No. Courts automatically enter judgment but generally issue a CoF only on request and after fees are paid.

Q 2. Can I ask for a CoF while a motion for reconsideration is pending?

No; the judgment is not yet final. The clerk will deny the request.

Q 3. What if an appeal was filed out of time?

The appeal is dismissible for tardiness, but until the dismissal becomes final, the clerk cannot issue a CoF.

Q 4. Do I need a CoF to execute a money judgment?

The sheriff may rely on the Entry of Judgment; a CoF is often required only when another body (BIR, LRA, PSA) needs proof.

Q 5. How do I get a CoF for a dismissed criminal case?

Same process. It is wise to secure one for immigration clearance purposes.

Q 6. Can I authenticate a CoF for use abroad?

Yes. After obtaining the CoF, take it to the RTC Executive Judge for red-ribbon / apostille authentication under the Apostille Convention (DFA-OCA).

13 Conclusion

A Certificate of Finality is often the last—but crucial—step that lets you enforce, register, or recognize a Philippine judgment. Its issuance is essentially ministerial once the time to appeal has lapsed, yet courts will only release it upon proper request, complete documents, and payment of fees. By understanding the reglementary periods, preparing the correct paperwork, and coordinating with the clerk of court, you can secure a CoF quickly and avoid costly delays in land registration, family-law compliance, corporate actions, or foreign enforcement. Always double-check deadlines, keep meticulous proof of service, and be courteous to court staff—their assistance is your fastest route to a final, enforceable victory.

How to Get Certificate of Finality Philippines