Montebon v. Court of Appeals
REITERATIONFacts
The Antecedents: Jose Rizal Lopez initiated an ejectment and damages case against Lydia Montebon, alleging that Montebon failed to pay P20,000.00 in monthly rentals for a residential/commercial unit located at 1459 Paz Street, Paco, Manila. The accumulated back rentals amounted to P384,900.00. Despite demands, Montebon refused to pay, prompting Lopez to file the lawsuit. Procedural History: The Metropolitan Trial Court (MeTC) ruled in favor of Lopez on December 27, 2005, ordering Montebon to vacate the premises at 1457 Paz Street, Paco, Manila, and to pay back rentals, current rentals, attorney's fees, and costs. Montebon appealed but failed to file a supersedeas bond. Consequently, Lopez filed a motion for execution pending appeal, which the Regional Trial Court (RTC) granted. The RTC later corrected the address in the writ of execution from 1457 to 1459 Paz Street, Paco, Manila, upon motion by Lopez. After Montebon failed to submit a proposal for liquidation of past due rentals, the RTC ordered the implementation of the alias writ of execution, leading to a Notice to Vacate Premises. Montebon then filed a petition for certiorari with the Court of Appeals (CA), assailing the RTC's orders and the writ of execution. The CA dismissed the petition for lack of merit. The Petition: Petitioner Lydia Montebon seeks review on certiorari of the CA's decision and resolution, arguing that the CA erred in ruling that the RTC did not commit grave abuse of discretion in granting the motion to correct the address in the writ of execution and in issuing the alias writ pending appeal. Montebon contends that the MeTC decision was defective due to the erroneous address and that the RTC could not issue a writ of execution based on a flawed decision. She asserts that the RTC should have allowed the MeTC to correct its error before seeking execution, as the writ must conform to the original judgment.
Issue(s)
Whether the Court of Appeals committed an error of law in ruling that the Regional Trial Court did not commit grave abuse of discretion when it granted the motion to correct the address indicated in the Metropolitan Trial Court's decision and subsequently issued an alias writ of execution pending appeal on the corrected address. Whether the Court of Appeals committed an error of law in not finding that the decision of the Metropolitan Trial Court is defective for containing an erroneous address of the subject premises.
Ruling
The petition is denied. The Court of Appeals' Decision dated May 9, 2007 and Resolution dated November 13, 2007 are affirmed.
Ratio Decidendi
On the issue of correcting the address and issuing an alias writ of execution pending appeal: The Supreme Court affirmed the CA's ruling that the RTC did not commit grave abuse of discretion. The Court held that the RTC acted within its inherent power to amend and control its processes and orders to make them conformable to law and justice. At the time the motion for execution pending appeal was filed, the RTC had already assumed jurisdiction over the case due to the pending appeal, rendering the MeTC no longer in a position to correct the error. Therefore, the duty devolved upon the RTC to rectify the error in the dispositive portion of the judgment sought to be executed. The Court emphasized that a clerical error or ambiguity in the dispositive portion of a judgment may be rectified or clarified by reference to the body of the decision itself and, suppletorily, to the pleadings previously filed. The RTC's action of issuing the writ with the correct address did not veer away from the MeTC judgment, as the complaint clearly identified the subject property as 1459 Paz St., Paco, Manila, where the petitioner resided and conducted business, while the private respondent's representative resided at 1457 Paz St., Paco, Manila. On the issue of the MeTC decision being defective due to an erroneous address: The Supreme Court found this argument without merit. The Court reiterated that a judgment is not rendered defective solely because of a typographical error in the dispositive portion; the judgment remains valid and subject to execution. The RTC's correction of the address was a proper exercise of its power to ensure that the writ of execution conformed to the actual subject matter of the case as established by the evidence and pleadings, thereby making the process conform to law and justice. The petitioner's attempt to use this alleged defect to unjustly prevent the execution of the MeTC judgment was deemed unmeritorious.
Main Doctrine
A court has the inherent power to amend and control its processes and orders to make them conform to law and justice, which includes the rectification of a clerical error in the dispositive portion of a judgment, such as an incorrect address, by reference to the body of the decision and pleadings.