GR 138993; (June, 2003) (Digest)
G.R. No. 138993; June 27, 2003
PHILIPPINE VETERANS BANK, Petitioner, vs. HON. SANTIAGO G. ESTRELLA & SOLID HOMES, INC., Respondents.
FACTS
Solid Homes, Inc. (SHI) filed a complaint against Philippine Veterans Bank (PVB) for specific performance and damages. The Regional Trial Court (RTC) granted SHI’s motion for summary judgment on February 22, 1994. A discrepancy existed between the original copy of the resolution in the court records and the copies served on the parties regarding the interest rate on a judgment debt of ₱28,937,965.65. The original record showed an 18% per annum interest rate, while the parties’ copies indicated 8%. PVB’s subsequent petitions challenging the 8% rate were dismissed by the Court of Appeals and the Supreme Court, making the February 1994 resolution final and executory.
Thereafter, SHI filed a Motion for Clarification, alleging that the “18%” figure in the original record was a surreptitious handwritten alteration of an original “8%.” The RTC, in an Order dated May 6, 1999, granted SHI’s motion and clarified that the correct interest rate was 8% per annum. PVB filed the instant petition for certiorari, arguing the RTC committed grave abuse of discretion in issuing the clarification order.
ISSUE
Whether the Regional Trial Court committed grave abuse of discretion in issuing its May 6, 1999 Order clarifying that the interest rate in its final and executory February 22, 1994 Resolution was 8% per annum.
RULING
The Supreme Court DISMISSED the petition, finding no grave abuse of discretion. The Court ruled that the assailed May 6, 1999 Order was a valid clarification, not an amendment, of a final judgment. A final judgment can be clarified or corrected to reflect its true intent, especially to rectify an apparent falsification in the record. The RTC, in the exercise of its inherent supervisory powers over the execution of its final judgments, acted properly to resolve the patent discrepancy between the court’s original record and the copies received by the litigants.
The legal logic is grounded in the principle of finality of judgments and the court’s ancillary jurisdiction to ensure their proper execution. While a final judgment cannot be substantively altered, a court retains the authority to clarify ambiguous or erroneous clerical entries to make the judgment conform to what was actually decided. Here, the RTC’s action merely ascertained and declared the true interest rate as contained in the copies served on the parties, thereby enforcing the judgment as originally promulgated and intended. This act of clarification did not constitute a modification affecting the substantive rights of the parties but was a necessary step to give effect to the final judgment.