G.R. No. 163208 ; August 13, 2008
HEIRS OF JUAN VALDEZ, SPS. POTENCIANO MALVAR and LOURDES MALVAR, petitioners, vs. THE HONORABLE COURT OF APPEALS and L.C. LOPEZ RESOURCES, INC., respondents.

FACTS

The petitioners, Heirs of Juan Valdez and Spouses Malvar, were plaintiffs in a civil case for quieting of title before the RTC of Antipolo. The RTC granted them a writ of preliminary mandatory injunction to possess a disputed parcel of land. The writ was enforced on March 24, 2003, against property claimed by respondent L.C. Lopez Resources, Inc., which was not a party to the underlying civil case. Lopez Resources filed a petition for certiorari and prohibition with the Court of Appeals, docketed as CA-G.R. SP No. 76286, challenging the RTC’s orders.
On May 5, 2003, the CA Ninth Division issued two conflicting resolutions in the same case. The first resolution dismissed the petition without prejudice due to a defective certification against forum shopping. The second resolution, issued the same day, required the petitioners to comment on the petition and directed Lopez Resources to rectify the certification deficiency. Lopez Resources received the dismissal resolution and subsequently re-filed a corrected petition, docketed as CA-G.R. SP No. 77615. The CA later issued an August 1, 2003 Resolution clarifying that the dismissal was a clerical error and that the operative resolution was the one requiring comment.

ISSUE

Whether the Court of Appeals acted with grave abuse of discretion in issuing the August 1, 2003 Resolution which clarified that its May 5, 2003 dismissal was a clerical error and effectively reinstated the petition in CA-G.R. SP No. 76286.

RULING

The Supreme Court ruled in the negative and upheld the CA’s actions. The issuance of two conflicting resolutions on the same day was a patent clerical error. The CA properly exercised its inherent power to correct such errors to ensure that its records reflect its true intent and to promote the orderly administration of justice. The Court emphasized that a clerical error involves a mistake in the transcription or recording of a judgment, not an error in the judicial reasoning itself.
The logic of the ruling is that the CA’s subsequent clarification was a valid nunc pro tunc correction. The second May 5 resolution, which required comment, demonstrated the division’s actual intent to give due course to the petition contingent on curing the formal defect. The act of re-filing by Lopez Resources was rendered unnecessary by this correction, but it did not prejudice the petitioners, as the substantive issues remained the same. The Court found no grave abuse of discretion, as the CA’s action was a reasonable measure to rectify a procedural mishap and did not violate the petitioners’ right to due process, as they were still afforded opportunity to file their comment. The existence of the re-filed case (CA-G.R. SP No. 77615) was deemed a superfluity arising from the error.