Case Digest (G.R. No. L-48322)
Facts:
The case revolves around a petition for certiorari lodged by Felicito Baguio and Neofita Simbajon against the Honorable Acting Presiding Judge Rosendo B. Bandal, Jr., of the Regional Trial Court of Negros Oriental, Branch 30, Dumaguete City, along with various respondents. The initial controversy emerged from Civil Case No. 4622, a case concerning the annulment of documents, partition, accounting, and damages. A Decision was rendered on October 12, 1987, by then-Presiding Judge Enrique C. Garrovillo, ordering the defendants to deliver possession of a property categorized as Lot No. 1868, PLS-321 to the plaintiffs, along with requiring a partition of the property among the heirs. This decision became final and executory on December 20, 1994. In subsequent developments, on September 12, 1995, the court issued a writ of execution upon the plaintiffs' motion for enforcement. The defendants later filed a motion to quash the writ, arguing that the property was not in th
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Case Digest (G.R. No. L-48322)
Facts:
- Background of the Case
- The case arose from Civil Case No. 4622, an action for annulment of documents, partition, accounting, and damages.
- The petitioners, Felicito Baguio and Neofita Simbajon, challenged orders rendered by the Regional Trial Court (Branch 30, Dumaguete City) in relation to the final and executory judgment issued in the case.
- The Initial Judgment
- On October 12, 1987, Presiding Judge Enrique C. Garrovillo handed down a decision ordering:
- Defendants to deliver possession of a disputed lot (erroneously identified as Lot No. 1868, PLS-321) along with its improvements to the plaintiffs.
- Partition of Lot No. 1868 and quantification of its fruits and products, delineated by unequal shares among the heirs of several individuals as stated in the pleadings.
- This judgment became final and executory on December 20, 1994.
- Subsequent Developments
- On September 12, 1995, upon motion of the plaintiffs (private respondents), the RTC issued a writ of execution based on the final judgment.
- The petitioners (then defendants) moved on September 22, 1995 to quash the writ of execution, arguing their inability to comply because the lot was actually owned and possessed by the heirs of Flavia Factoran.
- In response, the court on a subsequent motion (filed February 25, 1996 by the plaintiffs) amended the dispositive portion of the October 12, 1987 decision, clarifying that the lot in controversy was Lot No. 1898, not Lot No. 1868.
- The amendment was supported by evidence in the pleadings and prior amended complaints, all of which indicated that the correct lot number was 1898.
- The court justified its action by citing the rule that a final and executory judgment may be corrected for harmless clerical or typographical errors.
- Motion for Reconsideration and Filing of the Petition
- On June 3, 1996, petitioners filed a Motion for Reconsideration challenging the Order that had amended the judgment.
- Their motion was denied on August 22, 1996.
- Accordingly, the petition for certiorari was filed under Rule 65 seeking annulment of:
- The amended Order of the RTC amending the dispositive portion of the final judgment, and
- The denial of their Motion for Reconsideration.
Issues:
- Whether the respondent court erred by amending the dispositive portion of its final and executory judgment, specifically by correcting the lot number from 1868 to 1898.
- Was there a grave abuse of discretion in making such an amendment after the judgment had become final?
- Did the amendment alter the substance of the judgment or merely clarify a harmless clerical/typographical error?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)