G.R. No. 142345 ; August 13, 2004
THE HEIRS OF FERRY BAYOT, petitioners, vs. ESTRELLA BATERBONIA and ANGEL BATERBONIA, respondents.
FACTS
The dispute involves adjacent lots in the Buayan Townsite Subdivision. Estrella Baterbonia acquired Lot No. 4118 under the approved 1959 Cagampang survey. Ferry Bayot later acquired the adjacent Lot No. 4117 under the same survey. A subsequent resurvey by the Calina office altered the lot numbers but was never approved by the Bureau of Lands. Relying on this unapproved resurvey, Baterbonia applied for and obtained a Miscellaneous Sales Patent and an Original Certificate of Title (OCT) for “Lot No. 4117” under the Calina survey. The technical description on her OCT, however, corresponded to her actual property: Lot No. 4118 of the approved Cagampang survey.
In 1989, Bayot sued for reconveyance, claiming Baterbonia’s title covered Bayot’s actual Lot No. 4117. The trial court and the Court of Appeals dismissed Bayot’s complaint, finding Baterbonia owned the land described in her title. However, both courts, in the body of their decisions, directed Baterbonia to file a petition to amend her OCT’s lot number from “4117 (Calina)” to “4118 (Cagampang)” to avoid confusion. This directive was omitted from the dispositive portion (fallo) of the CA decision, which became final. Baterbonia never complied with the directive. Bayot’s heirs later filed a motion for clarification to compel compliance.
ISSUE
Whether the Court of Appeals can clarify or amend its final and executory decision to include in the dispositive portion the earlier directive for the respondents to file a petition for amendment of title.
RULING
Yes, the Supreme Court granted the petition. The legal logic rests on the principle that a final judgment can be amended to correct a clerical error or an inadvertent omission to make it conform to the body of the decision and effectuate its intent. The courts below had unequivocally found that Baterbonia’s OCT contained a lot number based on an unapproved survey, creating a potential for confusion, and thus ordered its amendment for clarity. This substantive ruling in the decision’s body was inadvertently omitted from the dispositive portion.
Such an omission is a clerical error that can be rectified even after finality, as it does not constitute a substantial alteration of the judgment. The amendment merely enforces what was already decreed in the decision’s reasoning. The Court emphasized that technicalities must yield to substantial justice. Therefore, to give complete effect to the lower courts’ findings and prevent future conflict, the Supreme Court ordered the amendment of the CA decision’s fallo and directed Baterbonia to file the petition for correction of the lot number on her title within thirty days.
