G.R. No. 143027 . March 31, 2006
ENCARNACION L. CUIZON and SALVADOR CUIZON, Petitioners, vs. MERCEDES C. REMOTO, LEONIDA R. MEYNARD, CELERINA R. ROSALES, and REMEDIOS C. REMOTO, Respondents.

FACTS

The case originated from an action for reconveyance filed by respondents against petitioners over a parcel of land. The Regional Trial Court ordered the reconveyance of the property to respondents, a decision affirmed by the Court of Appeals. The Supreme Court, in its Decision dated October 11, 2005, dismissed the petitioners’ petition and affirmed the CA decision, thereby sustaining the order for reconveyance. However, in its ruling, the Supreme Court made a specific factual finding regarding the exact area subject to reconveyance.
The Court found that the property sold by Placida Tabada-Lambo to respondents under a 1968 Deed of Sale of Real Property pertained only to her one-fourth (1/4) share in a larger 16-hectare co-owned property. Consequently, the area sold and thus subject to reconveyance should only be 4,000 square meters, not the 4,300 square meters indicated in the deed. The dispositive portion of the October 11, 2005 Decision, however, did not expressly incorporate this modification on the area. Petitioners thus filed a Motion for Reconsideration and/or Modification, seeking to have the dispositive portion explicitly modified to reflect the Court’s own finding that only 4,000 square meters should be reconveyed.

ISSUE

Whether the dispositive portion of the Supreme Court’s Decision dated October 11, 2005 should be modified to expressly state that the area to be reconveyed is limited to 4,000 square meters.

RULING

Yes, the dispositive portion is modified. The Court granted the petitioners’ motion. The legal logic is grounded on the principle that a dispositive portion of a decision must conform to and accurately reflect the findings and conclusions established in the body of the decision. The Court had already clearly determined, based on the evidence, that Placida Tabada-Lambo could only validly sell her proportionate share in the co-owned property. Since her share was one-fourth of 16 hectares (or 16,000 square meters), her alienable portion was precisely 4,000 square meters. The 1968 deed, while stating 4,300 square meters, could not convey more than what she legally owned. Therefore, the remedy of reconveyance ordered by the lower courts must be limited to that lawful portion. To avoid any ambiguity in execution and to align the final order with the substantive ruling, the Court modified its October 11, 2005 Decision. The amended dispositive portion now explicitly affirms the CA decision with the modification that the area covered by the 1968 deed pertains only to 4,000 square meters. This ensures that the judgment is executed in strict accordance with the Court’s factual and legal conclusions.