G.R. No. L-65334 December 19, 1986
MUNICIPALITY OF ANTIPOLO, petitioner, vs. AQUILINA ZAPANTA, et al., and the HONORABLE INTERMEDIATE APPELLATE COURT, respondents.

FACTS

This case originated from a land registration proceeding. The then Court of First Instance of Rizal, Branch XV, granted an application for registration in Land Registration Case No. N-9995, resulting in the issuance of certificates of title. The Municipality of Antipolo opposed this registration, claiming the land was part of the public domain. The trial court in a separate civil case (Civil Case No. 41353) later declared the registration decree null and void. The Intermediate Appellate Court (IAC) initially dismissed the Municipality’s appeal from that civil case on procedural grounds.
The Supreme Court, in its Decision of December 26, 1984, granted the Municipality’s petition. It set aside the IAC’s resolutions, directly acted on the appeal, and affirmed the trial court’s annulment of the land registration decree. However, a clerical error was present in paragraph (3) of the dispositive portion, which ordered the cancellation of titles issued in the name of the “Heirs of Isabela Avendaño.” The Municipality filed a Motion for Clarification, pointing out that the correct party in the registration case was the “Heirs of Joaquin Avendaño.”

ISSUE

Whether the Supreme Court may correct a clerical error in the dispositive portion of a final and executory decision.

RULING

Yes. The Supreme Court granted the Motion for Clarification and corrected the clerical error. The power to correct clerical errors or mistakes in judgments is inherent in courts and is explicitly provided for in the Rules of Court. A clerical error refers to a mistake or omission that is not the result of judicial reasoning or determination but arises from a minor mistake or inadvertence in the writing or transcription of the judgment.
The Court clarified that the error in naming “Isabela Avendaño” instead of “Joaquin Avendaño” was merely clerical. It did not affect the substantive ruling or the logic of the decision, which was to nullify the registration decree obtained by the heirs of the correct party, Joaquin Avendaño. The correction was necessary to accurately reflect the parties involved in the annulled registration proceeding and to ensure the proper implementation of the Court’s final judgment. The correction did not constitute an amendment of a substantial nature, which would be prohibited for a final judgment, but was a simple rectification to make the record conform to what was actually intended and adjudicated.