G.R. No. L-2582 February 27, 1951
TRINIDAD SEMIRA, ET AL., petitioners, vs. JUAN ENRIQUEZ, Judge, Court of First Instance of Batangas, ET AL., respondents.

FACTS

In Civil Case No. 43 of the Court of First Instance of Batangas, judgment was rendered in favor of the defendants on July 7, 1944. Plaintiffs’ counsel received notice on August 7, 1944, and filed a motion for reconsideration on August 30, 1944. After reconstitution of the record, the court denied the motion for reconsideration on May 26, 1948, with notice received by plaintiffs’ counsel on June 21, 1948. However, the court’s order mistakenly stated that the defendants filed the motion for reconsideration and the plaintiffs filed the opposition, when the opposite was true. On June 5, 1948, before receiving the notice of denial, plaintiffs’ counsel filed a motion for a 15-day extension to perfect an appeal should the motion for reconsideration be denied. Upon receiving the order of denial on June 21, 1948, plaintiffs filed a motion for correction of the clerical error. The court failed to act promptly on both the motion for extension and the motion for correction. On September 25, 1948, the court issued an order declaring the July 7, 1944 judgment final and executory, reasoning that the time for appeal had lapsed even if the extension were granted and that the motion for correction did not suspend the appeal period. Petitioners filed a mandamus action to compel judicial action on the motion for correction, set aside the September 25, 1948 order, and have the time for appeal declared suspended.

ISSUE

Whether the respondent judge had a duty to act promptly on the petitioners’ motion for correction of a clerical error in the order and motion for extension of time to perfect an appeal, and whether the failure to do so unfairly caused the judgment to become final and executory.

RULING

Yes. The Supreme Court granted the writ. The respondent judge was directed to correct the misstatement in the order of May 26, 1948. Petitioners were granted seven days from notice of the corrected order to perfect an appeal from the July 7, 1944 judgment. The Court held that litigants are entitled to expect action from the court on their motions, and the court has a duty to decide and resolve petitions promptly to allow parties to avail themselves of proper remedies. The inherent power of the court to amend its orders carries the concomitant duty to correct them. The petitioners timely called attention to the error and filed for an extension. The court’s subsequent inaction and ruling on finality, after admitting it could not dispose of the motions sooner, was unfair and unjust, making the petitioners suffer the consequences of judicial delay. The correction was necessary for the petitioners to file a proper record on appeal. (A subsequent resolution dated April 5, 1951, clarified that the respondent judge was not personally to blame for the delay, as he was holding sessions in other provinces when the motion was filed and only learned of it in September 1948.)