Short answer. Yes. Article 2044 expressly makes valid a stipulation that the arbitrators' award or decision shall be final. Such a clause is enforceable — but not beyond challenge: the article preserves the grounds on which even a compromise can be set aside, such as fraud, mistake or falsity discovered afterwards.
What the law says
Any stipulation that the arbitrators' award or decision shall be final, is valid, without prejudice to articles 2038, 2039, and 2040.
Civil Code, Article 2044 — Finality of the Arbitral Award. Read the full provision →
The parties can agree the award is the last word
Article 2044 answers the question in a single line: Any stipulation that the arbitrators' award or decision shall be final, is valid, without prejudice to articles 2038, 2039, and 2040. So a clause providing that whatever the arbitrator decides shall be final is not against the law; it is expressly authorised. Parties who submit a dispute to arbitration may agree that the award ends the matter, and the courts will respect that agreement rather than treat the award as a mere opinion to be re-litigated. The finality is a product of the parties' own stipulation, and the article gives it legal effect.
Why finality is allowed at all
Arbitration is a substitute the parties choose for a court trial, and finality is much of the point. A businessperson who agrees to arbitrate usually wants a quick, private and conclusive result, not a first round to be fought over again before a judge. If either side could reopen the merits at will, the arbitration would add a stage rather than replace one. Article 2044 protects that expectation: by validating a finality clause it holds the parties to the bargain they struck, so that having agreed to let an arbitrator decide, they cannot simply disown an award they dislike and demand a fresh hearing on the same facts.
The saving clause: final is not immune
Final does not mean untouchable. The article makes the finality without prejudice to the same escape routes the law keeps open for a compromise — because a submission to arbitration is treated much like one. Those grounds cover things such as fraud, mistake, duress or forgery affecting the agreement, a matter already conclusively decided, or the later discovery that the documents on which it rested were false. In other words, a party is not asserting the arbitrator was simply wrong; it is attacking the integrity of the process or the award on limited, defined bases. Ordinary disagreement with the outcome is not among them.
What a finality clause gets you, and does not
The practical upshot is a narrow window. A validly stipulated final award binds the parties and is meant to be enforced, not re-argued, so a party who lost cannot obtain what amounts to an appeal on the merits by dressing it up as a complaint. What it can do is invoke the specific, exceptional grounds the article preserves, and only where the facts genuinely fit them. Before agreeing to a finality clause, understand that you are trading the right to a second look for speed and certainty; and if you are challenging an award, identify at the outset which recognised ground you actually rely on, because a bare claim of error will not open the door.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Korea Technologies Co., Ltd. vs. Hon. Alberto A. Lerma, et al, G.R. No. 143581, January 7, 2008 — read the decision on LawPhil →
- Asset Privatization Trust vs. Court of Appeals, et al, G.R. No. 121171, December 29, 1998 — read the decision on LawPhil →