GR 52482; (February, 1990) (Digest)
G.R. No. 52482 February 23, 1990
SENTINEL INSURANCE CO., INC., petitioner, vs. THE HONORABLE COURT OF APPEALS, HON. FLORELIANA CASTRO-BARTOLOME, Presiding Judge, Court of First Instance of Rizal, Seventh Judicial District, Branch XV, THE PROVINCIAL SHERIFF OF RIZAL, and ROSE INDUSTRIES, INC., respondents.
FACTS
Petitioner Sentinel Insurance Co., Inc., acted as surety for Nemesio Azcueta, Sr., guaranteeing a credit line with private respondent Rose Industries, Inc. Azcueta defaulted on payments for purchased goods. Rose Industries filed a collection case. The parties agreed to submit the case for summary judgment. The trial court rendered a decision with a dispositive portion ordering payment of “interest on the principal obligation at the rate of 14% per annum at the rate of 2% every 45 days.” After the judgment became final and executory, Sentinel moved for clarification, arguing the phrasing imposed both 14% per annum interest and an additional 2% every 45 days, resulting in a usurious total. The trial court denied the motion, stating it could no longer amend a final judgment. Sentinel then filed a petition for certiorari with the Court of Appeals.
ISSUE
Whether the Court of Appeals correctly granted the petition for certiorari to order the clarification of the trial court’s dispositive portion to correct a clerical error.
RULING
Yes. The Supreme Court affirmed the Court of Appeals. The legal logic is anchored on the established exception that a court retains jurisdiction to correct clerical errors in a final and executory judgment. A clerical error is one visible to the eyes or obvious to the understanding; it involves a mistake in transcription that does not affect the court’s intended ruling. Here, the error was clerical. The complaint’s prayer sought “interest at 14% per annum and damage dues at the rate of 2% every 45 days.” The trial court’s dispositive portion, however, omitted the term “damage dues,” making the 2% charge appear as an additional interest component, leading to a potentially usurious interpretation. The correction merely aligns the dispositive portion with the relief sought in the complaint and the court’s evident intent, as discernible from the records. The amendment does not alter the substantive rights of the parties but merely clarifies the judgment to reflect that the 2% charge is a stipulated penalty or damage dues, not additional interest. Therefore, the Court of Appeals properly exercised its corrective power.