G.R. No. 46470; September 27, 1939
JUAN CASTILLO, applicant, vs. THE DIRECTOR OF LANDS and LA UNION AGRICOLA Y PECUARIA DEL SUR DE LUZON, oppositors; LA UNION AGRICOLA Y PECUARIA DEL SUR DE LUZON, petitioner-appellant; THE DIRECTOR OF LANDS, petitioner-appellee.

FACTS

On June 30, 1920, the sales application of La Union Agricola y Pecuaria del Sur de Luzon to purchase 1,024 hectares of grazing land from the Government was approved. It also acquired three adjoining parcels of rice land from private individuals, consolidated as Lot No. 12. Later, Juan Castillo applied for registration of parcels that included the corporation’s grazing land and Lot No. 12. Both the corporation and the Director of Lands opposed. The Court of First Instance and the Court of Appeals denied Castillo’s application, finding the lands to be public land subject to the corporation’s purchase rights. After remand, the corporation moved for an amplification of the decision to expressly declare it as owner of Lot No. 12, but the lower court denied the motion.

ISSUE

Whether the lower court erred in denying the corporation’s motion to correct or amplify its decision to expressly recognize the corporation’s ownership of Lot No. 12.

RULING

No. The denial is affirmed. The error sought to be corrected was not merely clerical. The lower court’s original decision explicitly included Lot No. 12 as part of the grazing land purchased from the Government. To exclude it would alter the court’s findings, which is not permissible at that stage of the proceedings. However, the Supreme Court noted that the Government did not contest the corporation’s claim over Lot No. 12 and suggested that the corporation may seek appropriate administrative relief to have its claim recognized, considering the constitutional limit on land acquisition by corporations and the principle against unjust enrichment.

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