Rebuldela v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Spouses Jovito and Cristina Rebuldela obtained a loan from the private respondents, initially for P19,500.00, secured by a real estate mortgage. This loan was later increased to P32,000.00 through an amended mortgage. The Rebuldelas failed to pay the loan within the stipulated period, prompting the private respondents to initiate an extra-judicial foreclosure of the mortgaged property. During the auction, the private respondents were the sole bidders, purchasing the property for P46,835.00, and a Sheriff's Certificate of Sale was issued and annotated on the title. Procedural History: Following the foreclosure and sale, the Rebuldelas filed a case seeking to set aside the extra-judicial foreclosure and sheriff's sale, and to redeem the property, alleging fraud. The trial court initially rendered a decision in favor of the plaintiffs (Rebuldelas), ordering the defendants (private respondents) to pay them certain amounts. However, the trial court, upon motion by the private respondents, corrected its decision ex-parte to reflect that the plaintiffs should pay the defendants, citing a clerical error in designating the parties. The Rebuldelas moved to quash the writ of execution based on this correction, but their motion was denied. They then filed a petition for certiorari with prohibition or preliminary injunction with the Intermediate Appellate Court (IAC), which dismissed their petition. The IAC subsequently denied their motion for reconsideration. The Petition: The Rebuldelas filed a petition for review on certiorari with the Supreme Court, challenging the IAC's decision that affirmed the trial court's correction of its judgment. They argued that the trial court committed grave abuse of discretion by amending its decision ex-parte without notice or hearing, effectively reversing the judgment and making them liable to pay the mortgage. They also contended that the IAC erred in affirming this correction, arguing it was not a mere typographical error but a substantial change unsupported by facts and law. Furthermore, they raised issues regarding the alleged misrepresentation of the total obligation amount and the usurious interest charged, as well as the timely consignment of their payment and the withdrawal of the consigned amount.
Issue(s)
Whether the trial court committed grave abuse of discretion amounting to lack of jurisdiction when it corrected its decision ex-parte. Whether the Intermediate Appellate Court erred in affirming the trial court's correction of the decision ex-parte. Whether the trial court erred in ordering petitioners to pay respondents when petitioners had allegedly consigned the full mortgage obligation and the respondent had withdrawn the consigned amount. Whether the private respondent committed misrepresentation of facts regarding the total obligation, including alleged usurious interest.
Ruling
The petition is denied for lack of merit. The decision of the Intermediate Appellate Court is affirmed.
Ratio Decidendi
On the alleged grave abuse of discretion in correcting the decision ex-parte: The Court held that the trial court has the inherent power to amend and control its process and orders to make them conformable to law and justice. This power can be exercised even to disregard technicalities and amend an order or process that has not become final, in order to better serve the ends of justice. The correction made by the trial court, which involved rectifying clerical errors in the dispositive portion to align it with the body of the decision, was well within its power. The amendment was made before the decision became final, and it served to correct the interchange of mortgagors and mortgagees, thereby conforming the judgment to the evidence presented. The Court cited established jurisprudence supporting the power of courts to correct clerical errors even after judgment has been entered, provided such errors are plainly due to inadvertence or negligence. Therefore, the assertion that the trial court committed grave abuse of discretion is untenable. On the alleged error of the Intermediate Appellate Court in affirming the trial court's correction: The Court found no error on the part of the IAC. The IAC correctly upheld the trial court's action, recognizing it as a rectification of clerical errors. The appellate court's affirmation was based on the principle that courts possess the inherent power to correct their own judgments to ensure they reflect the true intent and the evidence presented, especially when such corrections are made prior to the finality of the judgment. The IAC's reasoning that the trial court had the right to change its decision ex-parte because it was merely a typographical error was deemed supported by facts and law, as the error was indeed clerical and rectified to conform to the body of the decision. On the alleged error regarding payment and withdrawal of consigned amount: The Court found that the petitioners' claims regarding the loan amount and the alleged full payment were refuted by the mortgage contracts themselves. The records showed that the initial loan was P19,500.00, which was increased to P32,000.00 through an amended mortgage. The Court emphasized that public documents, like the amended mortgage, are entitled to full faith and credit and are presumed to be regular. To contradict them, clear, convincing, and more than merely preponderant evidence is required. The petitioners failed to present such evidence to dispute the terms of the amended mortgage. Therefore, the argument that the trial court should have reversed itself due to alleged full payment was not substantiated by the evidence on record. On the alleged misrepresentation of facts and usurious interest: The Court found no basis for the petitioners' claim of misrepresentation regarding the total obligation. The private respondents convincingly explained that while the principal mortgage obligation was P32,000.00, the total amount of P46,835.00 included expenses incurred in the extra-judicial foreclosure sale, such as costs of publication, interest, and attorney's fees. The Court reiterated the parol evidence rule, which prohibits the introduction of oral testimony to contradict the terms of a written agreement unless fraud or mistake is proven. The mortgage contracts were clear and unambiguous, and there was no showing of fraud or mistake. Oral testimony contradicting the written agreement was therefore inadmissible and could not prevail over the written contract. The Court concluded that the trial court correctly gave full faith and credence to the mortgage contracts.
Main Doctrine
A court has the inherent power to amend its orders and processes to conform to law and justice, especially when the amendment rectifies clerical errors and is made before the decision becomes final. The parol evidence rule bars the admission of oral testimony to contradict the clear and unambiguous terms of written mortgage contracts, absent fraud or mistake.