G.R. No. 176276 November 28, 2008
Philippine Health Insurance Corporation, petitioner, vs. The Court of Appeals and Chinese General Hospital and Medical Center, respondents.

FACTS

Respondent Chinese General Hospital and Medical Center (CGHMC) filed Medicare claims with the Social Security System for medical services rendered from 1989-1992 amounting to P8,102,782.10. Upon the enactment of Republic Act No. 7875, these pending claims were transferred to petitioner Philippine Health Insurance Corporation (Philhealth). Philhealth only paid P1,365,556.32 for the 1989-1992 claim. CGHMC also filed claims for 1998-1999 amounting to P7,554,342.93, which were denied for being filed beyond the allowed period. CGHMC filed a petition for review with the Court of Appeals (CA), which granted it and ordered Philhealth to pay the claims for both periods, totaling P14,291,568.71. This CA decision was affirmed by the Supreme Court in G.R. No. 163123 on April 15, 2005. However, the dispositive portion of the Supreme Court’s decision omitted explicit mention of the 1998-1999 claims, ordering payment only for “claims representing services rendered to its members from 1989 to 1992.” To satisfy the judgment, CGHMC filed a Motion for Execution with the CA. The CA initially granted execution but included a condition for CGHMC to submit pertinent documents. Upon CGHMC’s motion for partial reconsideration, the CA modified its resolution, ordering payment of the full P14,291,568.71 without the submission condition. Philhealth filed this Petition for Certiorari, arguing that the CA’s order to pay the 1998-1999 claims modified a final and executory judgment.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in ordering the payment of CGHMC’s claims for 1998-1999, despite the dispositive portion of the Supreme Court’s final and executory decision in G.R. No. 163123 omitting explicit mention of these claims.

RULING

The Supreme Court ruled that the Court of Appeals did not commit grave abuse of discretion. The omission of the “1998-1999” period in the dispositive portion of the Supreme Court’s decision in G.R. No. 163123 was a typographical error. The established doctrine is that when the dispositive portion of a final and executory judgment contains a clerical error or an ambiguity from an inadvertent omission, it may be clarified by reference to the body of the decision. The body of the affirmed CA decision clearly stated Philhealth’s liability for claims from both 1989-1992 and 1998-1999, amounting to P14,291,568.71. The CA rightly resorted to the decision’s entirety to clarify the ambiguity. Furthermore, the deletion of the condition requiring document submission was proper as such a condition was not found in the final decisions. Philhealth failed to demonstrate that the CA’s action was capricious, despotic, oppressive, or whimsical. The petition was dismissed and the assailed CA Resolutions were affirmed.