GR 179104; (February, 2008) (Digest)
G.R. No. 179104 ; February 29, 2008
ANASTACIO TUBALLA HEIRS, namely: JULIANA TUBALLA, AGUSTIN TUBALLA, and HERMAN TUBALLA, petitioners, vs. RAUL CABRERA, ET AL., respondents.
FACTS
Anastacio Tuballa, the registered owner of Lot No. 5697 covered by OCT No. FV-16880, filed a complaint for recovery of possession against Cabrera Enterprises. The RTC ruled in Tuballa’s favor but, in a clerical error, ordered the defendant to vacate “Lot No. 6597” in its dispositive portion. The Court of Appeals affirmed the RTC decision but deleted the monetary awards. This CA decision became final and executory.
Subsequently, Tuballa filed a manifestation with the RTC to correct the lot number from 6597 to 5697. The RTC denied the request, holding it had no authority to correct a decision of the Court of Appeals. Tuballa’s subsequent petition for certiorari and mandamus before the CA was dismissed on procedural grounds. The heirs of Tuballa then elevated the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the Supreme Court can correct a clerical error in the dispositive portion of a final and executory RTC decision that was affirmed by the CA.
RULING
Yes. The Supreme Court modified the RTC decision to correct the clerical error. The Court reiterated the doctrine of immutability of final judgments, which holds that a decision that has attained finality can no longer be altered, even to correct erroneous conclusions of fact or law. This principle is essential for the orderly administration of justice and to write finis to litigation.
However, the Court emphasized recognized exceptions to this rule: (1) the correction of clerical errors, (2) nunc pro tunc entries that cause no prejudice, and (3) void judgments. The transposition of digits from “5697” to “6597” in the RTC fallo constitutes a clerical error. This error is evident from the body of the complaint and the evidence, specifically OCT No. FV-16880, which consistently identifies the property as Lot No. 5697. The correction merely aligns the dispositive portion with the undisputed evidence and intent of the adjudicating court; it does not affect the substantive rights of the parties or alter the judgment on the merits. Therefore, the Supreme Court directly ordered the modification of the RTC decision to reflect the correct lot number.