G.R. No. L-22364 and L-28330, April 30, 1974
FILIPINO LEGION CORPORATION, petitioner, vs. THE COURT OF APPEALS, ENRIQUE LENTIJA, et al., respondents. ENRIQUE LENTIJA, et al., petitioners-appellants, vs. FILIPINO LEGION CORPORATION, defendant-appellee.

FACTS

Filipino Legion Corporation filed an action for recovery of possession and ownership over a 360-hectare land in Nabunturan, Davao, seeking to eject the respondents, Lentija, et al. The Corporation based its claim on a 1947 deed of absolute sale from Francisca S. Lacson and related tax declarations. Lentija, et al., occupants of portions of the land, defended that the land was part of the public domain and that they derived their rights from native Mansakas who were prior possessors. The trial court dismissed the Corporation’s complaint, upholding the defendants’ possession.
On appeal, the Court of Appeals, in a 1954 decision, modified the trial court’s ruling. It found that Lacson had proven prior possession of only approximately 48 hectares, not the entire 360 hectares claimed. The appellate court recognized the Corporation’s ownership over this 48-hectare portion and ordered the defendants therein to surrender it. However, due to a clerical error, the dispositive portion of this decision incorrectly referred to tax declaration exhibits, creating ambiguity over the exact land area awarded.

ISSUE

The core issue consolidated in these appeals was whether the Court of Appeals could correct a clerical error in the dispositive portion of its 1954 decision after it had become final and executory, to accurately reflect its declared findings on the area of land rightfully owned by the Corporation.

RULING

The Supreme Court ruled affirmatively, upholding the power of the court to correct clerical errors. The Court meticulously distinguished between a clerical error, which involves a minor mistake in transcription or oversight that does not affect the court’s intended ruling, and a judicial error, which pertains to an mistake in the court’s judgment or reasoning. The error in question—the misidentification of exhibit numbers in the dispositive portion—was deemed clerical. The body of the 1954 decision clearly and consistently stated the factual finding that Lacson (and thus the Corporation) had proven possession and ownership over only about 48 hectares, specifically detailing the constituent parcels. The dispositive portion’s reference to different exhibits was a mere inadvertence that inaccurately described the subject of the judgment.
The Court emphasized that such a correction does not alter the substantive rights adjudicated. The correction merely aligns the fallible order with the infallible decision, ensuring that the executed judgment conforms to what was actually decided. The power to make such corrections is inherent and can be exercised even after finality to promote equity and justice. Consequently, the Supreme Court affirmed the Court of Appeals’ resolution correcting the error and set aside a subsequent decision that had relied on the uncorrected dispositive portion, ultimately ruling that the Corporation was entitled only to the 48 hectares as originally found by the appellate court.