People v. Chan
REITERATIONFacts
1. The Antecedents: This case concerns a dispute that led to a decision by the Court of Appeals in CA-G.R. No. 00961-R. The specific underlying facts of this dispute are not detailed in the provided text, but the case originated from a matter that was appealed to the Court of Appeals. 2. Procedural History: The petitioner, Edilberto Chan, sought a review of the Court of Appeals' decision. Initially, this Court dismissed the petition on December 4, 1962, believing it was filed out of time. However, a subsequent certification from the Court of Appeals indicated the judgment entry date was September 6, 1962, not August 22, 1962, suggesting the petition was timely. This led to a resolution on December 21, 1962, setting aside the dismissal. 3. The Petition: Following the reconsideration of the filing timeliness, this Court reviewed the merits of Edilberto Chan's petition for review. Despite finding the petition to be timely filed, the Court ultimately determined that the petition lacked merit and resolved to deny it. A clerical error in the December 21, 1962 resolution incorrectly stated that a motion for reconsideration was denied, rather than the petition for review itself. This resolution now corrects that clerical error.
Issue(s)
Whether the Supreme Court may correct a clerical error in its own resolution. Whether the petition for review was filed on time.
Ruling
The Supreme Court corrected its resolution of December 21, 1962, to accurately reflect that the petition for review was denied on its merits, not a motion for reconsideration. The Court confirmed that the petition was filed on time.
Ratio Decidendi
On Whether the Supreme Court may correct a clerical error in its own resolution: The Supreme Court has the inherent power to correct clerical errors in its judgments or resolutions to make them conform to the true intention of the Court. Such corrections do not alter the substantive merits of the decision. In this case, the Court found a clerical error in its December 21, 1962 resolution, which mistakenly stated that a motion for reconsideration was denied instead of the petition for review itself. The Court explicitly stated that its resolution of December 21, 1962, suffered from a clerical error and proceeded to correct it to accurately reflect the denial of the petition for review on its merits. This power is essential for the integrity and accuracy of judicial records and ensures that the pronouncements of the Court are correctly recorded and implemented. The correction was made to align the written record with the Court's actual disposition of the case. On Whether the petition for review was filed on time: The Court determined that the petition for review was indeed filed on time. Initially, the petition was dismissed due to an erroneous report regarding the date of entry of the Court of Appeals' judgment. However, upon receiving a corrected certification from the First Deputy Clerk of the Court of Appeals, it was established that the date of entry, relevant to the petitioner, was September 6, 1962. Consequently, the petition for review, filed within the reglementary period from this corrected date, was considered timely. The Court's resolution of December 21, 1962, which set aside the earlier dismissal, was based on this finding of timeliness. Therefore, the subsequent denial of the petition was on its merits, not due to procedural defects like tardiness.
Main Doctrine
A resolution of the Supreme Court may be corrected if it contains a clerical error, provided that the correction does not alter the substantive merits of the original decision. In this instance, the Court corrected its previous resolution to accurately reflect that the petition for review was denied on its merits, not a motion for reconsideration, after confirming the petition was filed on time.