Filipino Legion Corp. v. Lentija
REITERATIONFacts
The Antecedents: The Filipino Legion Corporation (Corporation) filed an action for ownership and ejectment against Enrique Lentija, et al. (Lentija, et al.) over a 360-hectare land in Davao. The Corporation presented Exhibits C (deed of sale), D (tax declaration), E (affidavit), F, G, H, and I (tax declarations) to prove ownership. Lentija, et al. claimed the land was public domain and they acquired rights from native occupants. Procedural History: The Court of First Instance (CFI) dismissed the Corporation's complaint. The Court of Appeals (CA) modified the CFI decision, recognizing the Corporation's prior possession and better right to parcels of land described in Exhibits I, C, D, and E, ordering Lentija, et al. to vacate. Lentija, et al. appealed to the Supreme Court (SC) in G.R. No. L-8047, which was dismissed for being factual and unsubstantial. Subsequently, the Corporation sought execution of the CA decision. Lentija, et al. opposed, arguing the CA decision only recognized 48 hectares. The CFI granted execution. Lentija, et al. appealed to the CA (CA-G.R. No. 29274-R), which affirmed the CFI orders. Meanwhile, Lentija, et al. filed a motion with the CA in CA-G.R. 9196-R to correct clerical errors in the March 15, 1954 decision, praying that Exhibits I, F, G, and H (totaling 48 hectares) be identified instead of Exhibits I, C, D, and E. The CA granted this correction on November 8, 1963. The Corporation moved for reconsideration, arguing the correction affected substantial rights, but it was denied. The Petition: G.R. No. L-22364 is a petition for certiorari by the Corporation assailing the CA's Resolution correcting the dispositive portion of its March 15, 1954 decision. G.R. No. L-28330 is a petition for review by Lentija, et al. assailing the CA's Decision affirming the CFI's order of execution based on the original dispositive portion.
Issue(s)
Whether the Court of Appeals' Resolution of November 8, 1963, correcting the phrase "Exhibits I (Exh. 1), C, D and E" to "Exhibits I (Exh. 1), F (Annex C), G (Annex D), and H (Annex E)" in its March 15, 1954 decision, constituted a valid correction of a clerical error or an alteration of the substance of the judgment. Whether the principle of res judicata or laches precluded the correction of the alleged clerical error in the dispositive portion of the CA-G.R. 9196-R decision. What effect the correct and proper construction of the CA-G.R. 9196-R decision has on the writ of execution and demolition issued by the Court of First Instance of Davao.
Ruling
The Supreme Court ruled that the Court of Appeals did not err in correcting the clerical error in its March 15, 1954 decision. The Resolution in CA-G.R. 9196-R dated November 8, 1963, is AFFIRMED. Consequently, the Decision in CA-G.R. 29274-R, promulgated on September 26, 1967, is SET ASIDE. Costs against the Filipino Legion Corporation.
Ratio Decidendi
On Issue 1: The Court held that the correction was a valid rectification of a purely clerical error and did not alter the substance of the judgment. It reasoned that the original CA decision, when read as a whole, clearly indicated that the Corporation's claim was only partially established, covering approximately 48 hectares. The court meticulously analyzed the body of the 1954 CA decision, noting that it enumerated specific tax declarations (Exhibits F, G, H, I) covering 48 hectares, and explicitly stated that this total "would be far from the 360 hectares" claimed. The erroneous reference to Exhibits C, D, and E in the dispositive portion was attributed to an inadvertent use of their "Annex" labels (C, D, E) instead of their actual exhibit letters (F, G, H). The Court explained that Exhibit C was a deed of sale for 360 hectares, Exhibit D was a tax declaration for 360 hectares, and Exhibit E was an affidavit, none of which supported the 48-hectare finding, and their combined area (732 hectares) was even more than the 360 hectares originally claimed. Thus, the error was a clear case of misidentification of documents and not a judicial error involving the exercise of discretion or judgment. Citing Freeman on Judgments, the Court emphasized that mistakes in description, like designating lots by wrong numbers or giving wrong figures, are recognized as clerical errors correctible by nunc pro tunc amendments. On Issue 2: The Supreme Court ruled that res judicata and laches did not apply to bar the correction of the clerical error. It clarified that while the dismissal of the petition for review in L-8047 rendered the CA decision final as to the Corporation's right over 48 hectares, the specific question of the erroneous identification of exhibits in the dispositive paragraph was not raised in Lentija, et al.'s motion for reconsideration or the subsequent certiorari petition (L-8047). Consequently, this matter was not passed upon by either the Court of Appeals or the Supreme Court, and thus, the principle of res judicata could not apply to it. Regarding laches, the Court found no undue delay on the part of Lentija, et al., noting that they vigorously opposed the writ of demolition as early as May 1956, immediately after the error became evident through the Corporation's attempt to execute over the larger area, and subsequently filed the motion for correction. The Court recognized that the existence of the error only became apparent when the execution was sought over an area greater than what was actually awarded by the body of the decision. On Issue 3: The Court concluded that the execution must conform to the corrected decision. It reiterated the general rule that the dispositive portion controls for execution purposes, citing cases like Archbishop of Manila vs. Director of Lands, et al., but also emphasized that where there is ambiguity caused by an omission or mistake in the dispositive portion, the court may clarify such ambiguity by an amendment even after the judgment had become final. For this purpose, the court may resort to the pleadings, findings of facts, and conclusions of law as expressed in the body of the decision, as established in cases like Locsin vs. Paredes, et al. and Republic of the Philippines, Tolentino Sr., et al. vs. Hon. de los Angeles, et al. The correction merely cured an ambiguity and rectified an inadvertent mistake, ensuring the dispositive portion aligned with the true findings and dispositions in the main body of the judgment. Therefore, the writ of execution issued by the CFI and affirmed by the CA in L-28330, which was based on the uncorrected text implying a 360-hectare award, was erroneous and had to be set aside to ensure equity and justice.
Main Doctrine
A clerical error in the dispositive portion of a final judgment, which is a mere mistake in the identification of exhibits due to inadvertence, can be corrected by the court even after the judgment has become final, provided the correction conforms to the body of the decision and the pleadings, and does not alter the substantive rights of the parties.