Baguio v. Bandal
REITERATIONFacts
1. The Antecedents: The underlying dispute in Civil Case No. 4622, an action for Annulment of Documents, Partition, Accounting, and Damages, concerned Lot No. 1898, PLS-321, situated in the barangay of Bagacayon, La Libertad, Negros Oriental. The original decision by the Regional Trial Court ordered defendants Felicito Baguio and Neofita Simbajon to deliver possession of the lot and its improvements to the plaintiffs and to partition the lot and its fruits among ten groups of heirs. 2. Procedural History: A Decision dated October 12, 1987, was rendered by the Regional Trial Court of Negros Oriental, Branch 30. This judgment became final and executory on December 20, 1994. On September 12, 1995, a writ of execution was issued upon motion of the plaintiffs. The defendants moved to quash this writ, claiming inability to comply because Lot No. 1868 was allegedly owned by the heirs of Flavia Factoran. Subsequently, the respondent court, presided over by Judge Rosendo B. Bandal, Jr., issued an Order amending paragraphs eight and nine of the original decision to correct the lot number from 1868 to 1898, citing clerical and typographical error. The defendants' Motion for Reconsideration of this amendment was denied on August 22, 1996. 3. The Petition: Petitioners Felicito Baguio and Neofita Simbajon filed a Petition for Certiorari under Rule 65 of the Revised Rules of Court, seeking to annul the respondent court's Order amending its final and executory judgment and the subsequent Order denying their Motion for Reconsideration. They argued that the respondent court acted with grave abuse of discretion in amending a final and executory judgment. The Supreme Court, however, found the error to be merely clerical and typographical, consistent with established jurisprudence allowing amendments for harmless errors in final judgments.
Issue(s)
Whether the respondent court acted with grave abuse of discretion in amending the dispositive portion of its final and executory judgment. Whether the amendment of Lot No. 1868 to Lot No. 1898 in the dispositive portion of the judgment constituted a correction of a harmless clerical or typographical error.
Ruling
The petition is dismissed for lack of merit. The Supreme Court found that the respondent court did not act with grave abuse of discretion. The amendment made by the RTC was considered a correction of a harmless clerical and typographical error, consistent with established jurisprudence.
Ratio Decidendi
On the issue of grave abuse of discretion in amending the dispositive portion of a final and executory judgment: The Supreme Court held that the respondent court did not act with grave abuse of discretion. The Court found nothing whimsical or capricious in the assailed action of the respondent court. The amendment was deemed the right thing to do under the circumstances, as the lot in controversy was clearly Lot No. 1898, as evidenced by the pleadings and the court's own recital of facts in the original decision. The inclusion of Lot No. 1868 was identified as a product of a harmless clerical and typographical error. The Court emphasized that a court may amend a final and executory judgment to correct harmless clerical or typographical errors. This principle is well-settled in Philippine jurisprudence, ensuring that judgments reflect the true intent of the court and the actual subject of the litigation, even after finality. On whether the amendment constituted a correction of a harmless clerical or typographical error: The Supreme Court affirmed that the error addressed by the RTC's orders was merely clerical and typographical. The Court noted that the lot in controversy was consistently referred to as Lot No. 1898 in the Amended Complaint, Third Amended Complaint, and the recital of facts in the original Decision. Lot No. 1868 unexpectedly appeared in the dispositive portion of the judgment dated October 12, 1987, and was not the subject of the legal controversy. Therefore, its presence in the dispositive portion was evidently a mistake. The Court reiterated the rule that a final and executory judgment may be amended for harmless clerical or typographical errors, citing Vda. de Reyes vs. Court of Appeals. Furthermore, the Court clarified that where an ambiguity arises from an omission or mistake in the dispositive portion of a decision, the court may clarify such ambiguity by an amendment even after the judgment has become final, citing Reinsurance Company of the Orient, Inc. vs. Court of Appeals and Hiyas Savings and Loan Bank vs. Court of Appeals.
Main Doctrine
A final and executory judgment may be amended to correct harmless clerical or typographical errors, or to clarify an ambiguity caused by an omission or mistake in the dispositive portion, without violating the principle of immutability of judgments.