G.R. No. L-8539, December 24, 1914
MARIA DEL CONSUELO FELISA ROXAS Y CHUIDIAN, petitioner-appellee, vs. RAFAEL ENRIQUEZ, ET AL., objectors-appellants.

FACTS:
On January 12, 1906, Maria del Consuelo Felisa Roxas y Chuidian filed a petition in the Court of Land Registration to register four parcels of land in Manila under the Torrens system. This case concerns only Parcel A, located in Binondo, bounded by Calle Escolta (north), the Pasig River (south), the estate of Pedro P. Roxas (east), and the estate of the heirs of Antonio Enriquez (west). The petition included a technical description and a survey plan (Exhibit A). A discrepancy existed between the petition and the plan: the petition stated the boundary line AB ran S. 44°30’ W, while the plan showed it as S. 46°30’ W (both 31.08 meters). The court, after due notice and hearing, granted the registration and issued Decree No. 614 on April 25, 1906, and the corresponding Original Certificate of Title No. 20 on May 3, 1906. The decree and title adopted the description from the plan (S. 46°30’ W).

Subsequently, Roxas discovered that the certificate omitted mention of the buildings on the land and that the plan did not close mathematically due to the discrepancy. She filed a petition to correct the certificate to include the buildings and to approve an amended plan that reconciled the technical description with the plan, ensuring proper closure. The heirs of Antonio Enriquez and other interested parties opposed, arguing that the amended plan altered boundaries and included additional land not originally claimed. The trial court granted Roxas’s petition, and the oppositors appealed.

ISSUE:
1. Whether the Court of Land Registration had jurisdiction to order the correction of the original certificate of title and the approval of an amended survey plan after the decree of registration had become final.
2. Whether the amended plan unlawfully enlarged the registered property or altered its boundaries to the prejudice of the oppositors.

RULING:
The Supreme Court AFFIRMED the trial court’s decision.

1. Jurisdiction to Correct Errors: The Court held that the Court of Land Registration retained jurisdiction under Section 112 of Act No. 496 (the Land Registration Act) to correct errors or omissions in a certificate of title, even after the decree became final. The omission of the buildings from the certificate was a clerical error correctable by petition. The discrepancy between the technical description in the petition and the survey plan was also a correctable error that prevented the plan from closing mathematically. The amended plan was intended merely to reconcile the description and ensure closure, not to alter the property’s boundaries or area.

2. No Enlargement or Alteration of Boundaries: The Court found that the amended plan did not add land or change the boundaries adjudicated to Roxas. The beginning point (Point A) and the boundaries (Calle Escolta, Pasig River, and the estates of Pedro P. Roxas and the heirs of Antonio Enriquez) remained exactly as originally described and decreed. The correction of the directional bearing of line AB from S. 46°30’ W (per the plan and decree) to S. 44°30’ W (per the petition) was a technical adjustment to achieve closure, without modifying the property’s actual limits. The trial judges, including the one who heard the original case, confirmed that no new land was included.

Additionally, the Court ordered the original certificate to be amended to expressly include the buildings on the land, as their omission was an error and registration of land presumptively includes improvements unless stated otherwise.

The petition of the Masonic Temple Association of Manila (another oppositor) was also denied for lack of sufficient grounds. Costs were awarded against the appellants.