Tuballa Heirs v. Cabrera
REITERATIONFacts
The Antecedents: Anastacio Tuballa filed a Complaint for Recovery of Possession of a parcel of sugar land, Lot No. 5697, covered by Original Certificate of Title (OCT) No. FV-16880. Tuballa alleged that he and his predecessors-in-interest had been in possession of the land since time immemorial and that he invested resources to convert it into private ownership. Sometime in 1982, employees of Cabrera Enterprises, Inc. intruded into the land without Tuballa's consent, despite his protests. Procedural History: The Regional Trial Court (RTC), Branch 36 in Dumaguete City, rendered a Decision on September 30, 1994, ordering Cabrera Enterprises to vacate Lot No. 6597 and turn over possession to Tuballa, along with damages and attorney's fees. The Court of Appeals (CA) affirmed the RTC Decision on October 25, 2002, but deleted the awards for actual damages and attorney's fees. The CA Decision became final and executory on March 7, 2003. Tuballa later filed a Manifestation before the RTC pointing out a typographical error in the dispositive portion of the RTC Decision, where Lot No. 6597 was erroneously stated instead of Lot No. 5697, which was consistent with the evidence. On January 3, 2006, the RTC issued an Order stating it had no power to correct the error in the CA Decision. Tuballa filed a Petition for Certiorari and Mandamus before the CA, which was dismissed due to procedural deficiencies. The CA denied his motion for reconsideration. The Petition: The children and heirs of Anastacio Tuballa filed the instant Petition for Review on Certiorari, seeking to correct the transposition of digits in the lot number in the dispositive portions of the CA and RTC Decisions to conform to Lot No. 5697 as supported by the evidence.
Issue(s)
Whether the RTC has the authority to correct a clerical error in its own decision after it has become final and executory, especially when the error was carried over to the appellate court's decision. Whether the transposition of digits in the lot number constitutes a clerical error that can be corrected under the exceptions to the rule on immutability of judgments.
Ruling
The Supreme Court granted the petition, modified the RTC Decision to correct the clerical error, and ordered the dispositive portion to reflect Lot No. 5697 instead of Lot No. 6597.
Ratio Decidendi
On the issue of correcting clerical errors in final judgments: The Court reiterated the principle that a decision that has acquired finality becomes immutable and unalterable. However, it also recognized exceptions to this rule, namely: (1) the correction of clerical errors, (2) the so-called nunc pro tunc entries which cause no prejudice to any party, and (3) void judgments. The Court emphasized that the orderly administration of justice requires that judgments reach a point of finality to write finis to disputes, and any act violating this principle must be struck down. This principle extends to all bodies exercising judicial powers. The Court stressed that utmost respect and adherence to this principle must always be maintained by those who exercise the power of adjudication. Any act that violates such principle must immediately be struck down. The Court further clarified that the principle of conclusiveness of prior adjudications is not confined to courts but extends to all bodies with judicial powers. On whether the transposition of digits constitutes a correctable clerical error: The Court found that the technical description of the land under OCT No. FV-16880 clearly refers to Lot No. 5697, Pls-659-D, and not Lot No. 6597. Therefore, the RTC committed a typographical or clerical error in its Decision when it ordered Cabrera Enterprises to vacate Lot No. 6597. This error was subsequently affirmed by the CA. Applying the first exception to the modification of final judgments, the Court held that it could modify the clerical error in the RTC Decision to make it conform to the actual lot number as evidenced by the title and the complaint. The Court explicitly stated that the correction of this clerical error does not alter the substantive merits of the case but merely rectifies a mistake in the transcription of the lot number, which was clearly identified as Lot No. 5697 in the title and the complaint filed by the plaintiff.
Main Doctrine
A clerical error in a final and executory judgment, such as a transposition of digits in a lot number, may be corrected by the court that rendered the decision, even after the judgment has become final, provided the correction is merely to make the judgment conform to the clear intent of the court and the evidence on record, and does not alter the substantive merits of the case.