G.R. No. 126442 December 29, 1998
Felicito Baguio and Neofita Simbajon, petitioners, vs. Honorable Acting Presiding Judge Rosendo R. Bandal, Jr., et al., respondents.

FACTS

Petitioners Felicito Baguio and Neofita Simbajon filed this Petition for Certiorari to annul two Orders of the Regional Trial Court (RTC) of Negros Oriental, Branch 30. The RTC had issued an Order amending the dispositive portion of its final and executory Decision dated October 12, 1987, in Civil Case No. 4622, an action for Annulment of Documents, Partition, Accounting, and Damages. The original dispositive portion ordered petitioners to deliver possession of “Lot 1868, PLS-321” to the plaintiffs (private respondents) and to partition the same. This judgment became final on December 20, 1994.
Upon motion for execution by the private respondents, petitioners moved to quash the writ, claiming they could not comply because Lot No. 1868 was owned by third parties. In response, private respondents filed a motion to amend the judgment, contending the lot number was a clerical error and the correct property subject of the litigation was Lot No. 1898. The RTC granted the motion, amending paragraphs 8 and 9 of its dispositive portion by changing “Lot No. 1868” to “Lot No. 1898.” Petitioners’ motion for reconsideration was denied.

ISSUE

Whether the respondent court acted with grave abuse of discretion in amending the dispositive portion of its final and executory judgment.

RULING

The Supreme Court ruled that the respondent court did not commit grave abuse of discretion. The amendment was proper as it merely corrected a clerical or typographical error. The legal logic is anchored on the settled doctrine that a final and executory judgment may still be amended to correct harmless clerical errors or to clarify an ambiguity caused by a mistake in the dispositive portion.
The Court examined the records and found that the pleadings, complaints, and the body of the RTC’s own Decision consistently referred to the contested property as Lot No. 1898. The appearance of “Lot No. 1868” in the dispositive portion was an inadvertent mistake that did not reflect the court’s actual adjudication. The correction did not alter the substantive rights of the parties or the essence of the final judgment; it merely made the dispositive portion conform to the evidence and the court’s factual findings as stated in the decision’s narrative. Therefore, the RTC’s act was a valid exercise of its inherent power to correct clerical errors to ensure its judgment accurately reflected its intended ruling. The petition was dismissed for lack of merit.