G.R. No. L-53560 March 30, 1982
Petra Gabaya, petitioner, vs. Hon. Rafael T. Mendoza, in his official capacity as Judge, CFI Cebu, Spouses Fulgencio Gabaya and Araceli L. Gabaya, respondents.

FACTS

Petitioner Petra Gabaya was a defendant in a complaint for recovery of possession filed by her brother, respondent Fulgencio Gabaya, over parcels of land adjudicated to him. Petra claimed a tenancy relationship, leading the trial court to refer the issue to the Department of Agrarian Reform (DAR). The DAR certified no tenancy relationship existed. The trial court subsequently granted Fulgencio’s motion for summary judgment, ordering Petra to surrender the land and remove her house or pay monthly rental. This judgment became final and was executed.
Subsequently, Fulgencio filed motions for contempt and for demolition of Petra’s house. In an Order dated November 6, 1979, the trial court, while denying the contempt motion, made a statement that Petra “is a tenant.” Later, on December 13, 1979, the court granted the demolition order. Petra moved for reconsideration, arguing the November 6 Order declaring her a tenant had become final and entitled her to a homelot under agrarian laws. The trial court, in an Order dated February 7, 1980, rectified its November 6 Order, clarifying it contained a “clerical error” and that the final judgment had already conclusively ruled she was not a tenant.

ISSUE

Whether the trial court acted with grave abuse of discretion in issuing the February 7, 1980 Order rectifying its previous November 6, 1979 Order.

RULING

No. The Supreme Court held the trial court did not commit grave abuse of discretion. The central legal principle is the immutability of final judgments. The summary judgment of May 3, 1978, which became final, conclusively settled that Petra was not Fulgencio’s tenant, as per the DAR certification incorporated therein. The November 6, 1979 Order, which contained a contradictory statement that she “is a tenant,” was a patent nullity. A final judgment can no longer be amended, except for clerical errors or where supervening events render its execution unjust. The statement in the November 6 Order was not a clerical error but a substantive mistake that effectively attempted to alter a final judgment. However, the trial court’s act of rectifying this error in its February 7 Order was a proper exercise of its inherent power to correct its own blatant mistakes to ensure its processes were not used to undermine a final ruling. The rectification did not modify the final judgment but merely clarified a subsequent erroneous order that was void for contradicting it. Petra’s reliance on agrarian laws was misplaced as her status as a non-tenant was already res judicata.