G.R. No. L-30787 August 29, 1974
PURIFICACION SANTOS IMPERIAL, petitioner, vs. HON. EMMANUEL M. MUÑOZ, and LUIS U. SANTOS, respondents.

FACTS

The case involves the intestate estate of Fermina Bello Santos. The known heirs are her surviving spouse, Luis U. Santos, and her adopted daughter, Purificacion Santos Imperial. In Special Proceedings No. 1049, the Court of First Instance of Bulacan, on June 6, 1967, approved an Amended Project of Partition awarding a 5/8 share of the estate to Luis and a 3/8 share to Purificacion. This order was followed by a Compromise Agreement on January 16, 1968, settling income shares, and a Final Partial Project of Partition on April 26, 1968, reiterating the 5/8 and 3/8 distribution.
Subsequently, on June 18, 1968, Luis filed a Motion for Correction, arguing the partition was erroneous under Article 996 of the Civil Code. He contended that as a surviving spouse concurring with only one legitimate child, he was entitled to one-half (1/2) of the estate, not 5/8, and the child should receive the other half (1/2), not 3/8. The trial court granted the motion, setting aside its prior orders to correct the distributive shares. Purificacion opposed, arguing the orders had become final and executory.

ISSUE

The primary issue is whether the trial court’s orders approving the project of partition had become final and executory, thereby precluding their correction.

RULING

The Supreme Court ruled in favor of the petitioner, Purificacion Santos Imperial. The Court held that the orders of June 6, 1967, and April 26, 1968, were final orders. Citing Santillon v. Miranda, the Court reiterated that an order determining the distributive shares of heirs is appealable. These orders definitively settled the proportion of the estate each heir would receive, making them final judgments on that matter.
Since the respondent, Luis U. Santos, did not appeal these orders within the 30-day reglementary period, they became final and executory. The Court emphasized the doctrine of finality of judgments, referencing Chereau v. Fuentebella, which states that an erroneous judgment is not void and, once final, is not subject to alteration. A court loses jurisdiction to amend or correct a final judgment except for clerical errors. The respondent’s failure to timely appeal constituted negligence, and the trial court acted without jurisdiction in granting the motion for correction after finality had set in. Consequently, the Supreme Court reversed the orders of the trial court dated February 18, 1969, and July 17, 1969.