Short answer. Yes. Under Rule 120, Section 7, a judgment of conviction becomes final when the accused has applied for probation — the same effect as letting the appeal period lapse, serving the sentence, or waiving appeal in writing. Applying for probation is therefore a choice against appealing, and it closes the window for modifying the judgment.
What the law says
a judgment becomes final after the lapse of the period for perfecting an appeal, or when the sentence has been partially or totally satisfied or served, or when the accused has waived in writing his right to appeal, or has applied for probation
Rule 120, Section 7 — Modification of judgment. Read the full provision →
The modification window
Section 7 gives a convicted accused a short-lived power: A judgment of conviction may, upon motion of the accused, be modified or set aside before it becomes final or before appeal is perfected. The window closes at finality — so everything turns on knowing exactly when a conviction becomes final. The section then lists the events that do it, and the list is where probation makes its appearance, alongside more obvious endings like the lapse of the appeal period.
Four events that finalise a conviction
The section names the triggers: Except where the death penalty is imposed, a judgment becomes final after the lapse of the period for perfecting an appeal, or when the sentence has been partially or totally satisfied or served, or when the accused has waived in writing his right to appeal, or has applied for probation. Read the company probation keeps. Serving the sentence, waiving appeal in writing — these are acts of acceptance, and the Rules place a probation application among them. Filing it is not a neutral procedural step; it is one of the events that finalise the conviction.
Why probation sits in that list
The logic is coherence: probation asks to serve the penalty in the community under conditions, which presupposes accepting the judgment that imposed the penalty. A person cannot simultaneously accept the sentence for supervised release and contest it on appeal, so the section makes the application itself a finality event. The practical consequence runs through everything that follows — once final, the conviction is no longer open to the modification the section's first sentence allows, and the ordinary route of appellate review is closed.
Decide once, with counsel, before filing
The decision therefore deserves to be made deliberately, and before anything is filed. The questions that matter: how strong are the grounds for appeal, what exposure does an appeal carry, and what does probation realistically offer in this case — because this section prices the application at the cost of finality. A convicted person weighing the options should bring the judgment and the sentencing terms to a lawyer immediately after promulgation, while the period for perfecting an appeal is still open and every road remains available.