G.R. No. 124280 June 9, 1997
FLORA S. REYES, petitioner, vs. HON. COURT OF APPEALS, AND HEIRS OF FELISA MARTIN-HIPOLITO, respondents.

FACTS

Elena B. De Jesus was the registered owner of a parcel of land covered by TCT No. 63308. On April 7, 1964, she sold the lot to petitioner Flora Reyes, who paid an initial sum and took possession, though the title remained in De Jesus’s name. On September 22, 1965, De Jesus obtained a loan from respondent Felisa Martin-Hipolito and mortgaged the same property, delivering the title but without registering the deed. On June 9, 1966, after Reyes paid the balance, De Jesus executed a deed of absolute sale in favor of Reyes, which was registered, leading to the cancellation of De Jesus’s title and the issuance of TCT No. 22321 in Reyes’s name. Hipolito filed an action (Civil Case No. 937) to cancel the sale and Reyes’s title. Reyes was declared in default, and a default judgment was rendered. The property was auctioned, with Hipolito as the highest bidder, and TCT No. 36702 was eventually issued in her name. Reyes later filed for annulment of the default judgment, which was granted, and the case was reopened. The trial court later held the sale between De Jesus and Reyes to be simulated, ordered the cancellation of Reyes’s title, and upheld Hipolito’s title. Reyes appealed to the Court of Appeals (CA-G.R. CV No. 26008), which reversed the trial court, declaring Hipolito’s title null and void and upholding Reyes’s title and deed of sale. Hipolito’s petition to the Supreme Court was dismissed. Upon execution, the Register of Deeds noted a discrepancy: the CA decision’s opening paragraph identified the land as “Lot No. 40, Block 33,” while the three TCTs (De Jesus, Hipolito, and Reyes) identified it as “Lot No. 40, Block No. 133.” Reyes filed a motion for correction of this typographical error in the CA, which was denied, leading to this petition.

ISSUE

Whether the Court of Appeals erred in denying the motion to correct a typographical error in its decision, specifically the discrepancy between “Block 33” and “Block 133” in the description of the subject property.

RULING

The Supreme Court granted the petition. It held that the discrepancy was merely a typographical error. The Court found that TCT Nos. 63308, 22321, and 36702 all refer to the same parcel of land, Lot No. 40, Block 133, and that the identity of the land was never in dispute throughout the proceedings. The Court ruled that clerical errors, mistakes, or omissions due to inadvertence or negligence may be corrected even after a judgment has become final. The Court set aside the CA resolutions denying the motion and ordered the CA to correct its decision by changing “Lot No. 40, Block No. 33” to “Lot No. 40, Block 133.”