GR L 20260; (March, 1963) (Digest)
G.R. No. L-20260; March 30, 1963
EDILBERTO CHAN, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
The Supreme Court initially dismissed the petition for review filed by Edilberto Chan on December 4, 1962, deeming it filed out of time. This dismissal was based on a prior report indicating the final judgment from the Court of Appeals was entered on August 22, 1962. Subsequently, a certification from the First Deputy Clerk of the Court of Appeals clarified that the correct date of entry of judgment concerning Chan was September 6, 1962. This correction established that Chan’s petition was actually filed within the prescribed period.
Consequently, the Court set aside its December 4 resolution on December 21, 1962, and proceeded to evaluate the petition on its merits. After consideration, the Court found the petition lacking in merit and resolved to deny it. However, the written resolution contained a clerical error, incorrectly stating that the Court was denying a “motion for reconsideration” instead of accurately reflecting the denial of the “petition for review.”
ISSUE
Whether the clerical error in the December 21, 1962 resolution, which misstated the nature of the pleading denied, should be corrected.
RULING
The Supreme Court granted the correction. The power to correct clerical errors is inherent in courts and is explicitly provided under Section 7 of Rule 120 of the old Rules of Court. A clerical error refers to a mistake or omission in a judgment arising from a minor inadvertence or oversight, which does not affect the court’s substantive reasoning or the actual decision rendered. It is an error in the recording or transcription of the judgment that does not reflect the court’s true intention.
In this case, the Court’s substantive ruling was to deny Chan’s petition for review after finding it without merit. The mislabeling of the pleading as a “motion for reconsideration” in the dispositive portion was a mere clerical mistake. This error did not alter the essence of the Court’s final adjudication, which was the denial of the petition for review itself. The correction merely aligns the text of the resolution with the Court’s manifest intent and actual decision, ensuring the record accurately reflects the proceedings. Therefore, the resolution of December 21, 1962, and its corresponding entry of judgment were officially rectified.