GR 24435; (August, 1977) (Digest)

G.R. No. L-24435. August 26, 1977.
CARMEN DEL ROSARIO ILACAD, ET AL., petitioners, vs. THE COURT OF APPEALS and PRUDENTIAL BANK & TRUST COMPANY, respondents.

FACTS

Prudential Bank filed a complaint for sum of money based on a promissory note against Lanuza Bay Lumber Co., Inc. and later amended it to include its President, Jose Ilacad, as a party defendant. After the defendants failed to appear at a scheduled hearing, the trial court decided the case based on the plaintiff’s evidence and dismissed the complaint. The Bank appealed to the Court of Appeals, which reversed the trial court’s decision in a May 25, 1964 decision, holding Jose Ilacad personally liable for P1,5000.00 with interest. This decision became final and executory, and an entry of judgment was issued. Subsequently, the Bank filed a motion to correct a clerical error regarding the placement of a comma in the principal amount (to read P15,000.00), which the Court of Appeals granted. Later, due to an issue with the writ of execution, the Bank filed a motion for clarification. The Court of Appeals then issued an amendatory decision and a subsequent amendatory resolution in November 1964, which clarified that defendant Jose Ilacad was liable for P15,000.00. Petitioners, as heirs of the deceased Jose Ilacad, sought to annul these amendatory issuances.

ISSUE

Whether the Court of Appeals acted without or in excess of jurisdiction or with grave abuse of discretion in issuing the amendatory decision and resolution after its original decision had become final and executory.

RULING

The Supreme Court dismissed the petition. The Court held that the amendatory decision and resolution were valid clarifications that did not alter the substantive rights adjudicated in the final judgment. A final judgment can generally no longer be altered, but exceptions exist for correcting clerical errors or making nunc pro tunc entries that cause the judgment to reflect the actual decision of the court. The original dispositive portion, despite a typographical error in the amount, clearly intended to hold Jose Ilacad liable for P15,000.00 based on the body of the decision. The subsequent issuances merely clarified this intent to prevent a miscarriage of justice and ensure proper execution. The amendments did not constitute a substantial change but were corrections to make the decretal portion conform to the court’s definitive findings. Furthermore, the petitioners could not claim extrinsic fraud, as there was no allegation that their predecessor was prevented from presenting his case due to fraudulent acts outside of trial. Therefore, the Court of Appeals acted within its jurisdiction in issuing the clarificatory amendments to give effect to its final judgment.