G.R. No. 126442 - Baguio vs. Bandal, Jr.

Case Summary (G.R. No. 126442)

Factual Background and Trial Court Decision

In Civil Case No. 4622, the Regional Trial Court’s October 12, 1987 Decision ordered, among others, that defendants Felicito Baguio and Neofita Simbajon deliver possession of Lot 1868, PLS-321, and the improvements thereon, to plaintiffs within fifteen days after the decision became final, and that it order the partition of Lot 1868, PLS-321 and the value of fruits and products from February 12, 1965 to the present, in the enumerated shares among ten groups of heirs.

The court’s judgment was premised on the controversy involving a specific parcel identified in the parties’ pleadings and evidence. Although the dispositive portion referred to Lot 1868, the later court records and the pleadings reflected that the lot actually litigated was Lot 1898, PLS-321 situated in Barangay of Bagacayon, La Libertad, Negros Oriental.

Finality and Issuance of Writ of Execution

The October 12, 1987 judgment became final and executory on December 20, 1994. On September 12, 1995, on motion of the plaintiffs (the private respondents), the respondent court ordered the issuance of a writ of execution.

Motion to Quash and Petitioners’ Position

On September 22, 1995, petitioners moved to quash the writ of execution. They anchored their motion on the alleged inability to comply, contending that Lot 1868 was then allegedly owned and possessed by the heirs of a certain Flavia Factoran. By this theory, petitioners sought to defeat execution on the ground that the subject property designated in the dispositive portion was not the one under their control.

Assailed Order Amending the Dispositive Portion

Acting on private respondents’ position, the respondent court issued the assailed Order dated May 9, 1996, amending paragraphs eight (8) and nine (9) of the October 12, 1987 decision. The order granted the motion praying that the lot number appearing in the judgment be amended: Lot 1868 was to be read as Lot 1898 so as to “conform to the evidence.”

The Regional Trial Court explained that the amended complaint and third amended complaint, as well as the prayer and the recitals of the decision, showed that the lot in controversy was Lot 1898, PLS-321. It further invoked the principle that a final and executory judgment may be amended on harmless clerical or typographical errors, citing Vda. de Reyes vs. Court of Appeals. It likewise relied on the doctrine that, where ambiguity exists in the dispositive portion because of omission or mistake, the court may clarify the judgment even after it becomes final, citing Reinsurance Company of the Orient, Inc. vs. Court of Appeals and Hiyas Savings and Loan Bank vs. Court of Appeals.

The dispositive change was explicitly framed as a correction: “Lot 1868, should be written and read as Lot 1898.”

Motion for Reconsideration and Denial

Petitioners sought reconsideration on June 3, 1996, but their Motion for Reconsideration was denied on August 22, 1996. The order denying reconsideration maintained that the lot in controversy was Lot 1898 and that Lot 1868 “suddenly cropped up” in the judgment. It concluded that Lot 1868 had “no bearing in this case” and was the product of a harmless clerical and typographical error.

Issue Raised in the Petition

Petitioners, in their Rule 65 petition, challenged whether the respondent court committed grave abuse of discretion in amending the dispositive portion of a final and executory judgment. The inquiry centered on whether the amendment substantively altered adjudication or merely corrected a technical and non-prejudicial error in the judgment’s dispositive portion.

The Parties’ Contentions

Petitioners argued, in substance, that the writ of execution anchored on the dispositive reference to Lot 1868 was erroneous because they could not comply, as the relevant property was allegedly held by other persons, specifically the heirs of Flavia Factoran. They thus sought nullification of the orders that allowed the dispositive portion to be amended after finality.

Private respondents, on the other hand, maintained that Civil Case No. 4622 concerned Lot 1898, and that the reference to Lot 1868 in the dispositive portion resulted from a clerical or typographical mistake that produced an ambiguity which could be clarified without impairing the finality of the judgment.

Legal Basis and Reasoning of the Supreme Court

The Court found the petition unmeritorious. It held that it discerned nothing whimsical or capricious in the respondent court’s action. The Court reasoned that the amendment addressed an error that was merely clerical and typographical and that it served to clarify the judgment in line with the pleadings and evidence establishing that the lot under litigation was Lot 1898.

The Court treated the respondent court’s correction as faithful to the actual subject of the case. It emphasized that Civil Case No. 4622 referred “to no other lot than Lot No. 1898,” and therefore the inclusion of Lot 1868 in the dispositive portion had no bearing beyond the mistaken naming of the property. The Court reiterated the controlling rule that a final and executory judgment may yet be amended on harmless clerical or typographical errors, and also recognized the court’s authority to clarify ambiguity caused by omission or mistake in

Case Syllabus (G.R. No. 126442)

Parties and Procedural Posture

Petitioners Felicito Baguio and Neofita Simbajon filed a Petition for Certiorari under Rule 65 to annul an Order of the Regional Trial Court of Negros Oriental, Branch 30, and a subsequent Order denying reconsideration.
Respondent is the Honorable Acting Presiding Judge Rosendo B. Bandal, Jr., Seventh Judicial Region, Regional Trial Court, Negros Oriental, Branch 30, Dumaguete City.
Respondents include the large group of plaintiffs in the court below, including Andres and all the other private individuals listed, and the guardians ad litem identified in the caption.
The underlying Civil Case No. 4622 in the trial court was an action for Annulment of Documents, Partition, Accounting, and Damages.
The trial court decision in that case was rendered by then Presiding Judge Enrique C. Garrovillo and later modified by the court through the assailed orders.
The petition sought to set aside the trial court’s post-judgment amendment of the dispositive portion of a final and executory judgment and the denial of petitioners’ Motion for Reconsideration.

Key Factual Allegations

The trial court’s October 12, 1987 decision ordered delivery of possession and partition relating to a lot denominated as Lot 1868, PLS-321 and the computation of fruits and products tied to the same lot.
The dispositive portion also required submission of a Partition Agreement for confirmation.
The decision became final and executory on December 20, 1994.
Respondents obtained an order for issuance of a writ of execution on September 12, 1995.
Petitioners moved to quash the writ of execution on September 22, 1995, asserting that compliance was impossible because Lot No. 1868 was allegedly owned and possessed by the heirs of Flavia Factoran.
The trial court then issued an assailed order amending paragraphs eight and nine of the 1987 judgment to make the lot number read Lot No. 1898 instead of Lot No. 1868.
Petitioners’ Motion for Reconsideration of the amendment was filed and later denied on August 22, 1996, prompting the Rule 65 petition.

Prior Trial Court Disposition

The October 12, 1987 decision contained dispositive orders directing delivery of possession of Lot 1868, PLS-321 and its improvements to the plaintiffs after finality.
The same decision ordered partition of Lot 1868, PLS-321, including computation of the value of fruits and products from February 12, 1965 to the present, in the shares corresponding to ten groups of heirs identified in the fourth amended complaint and related pleadings.
The court required the corresponding Partition Agreement to be submitted within a specified time after confirmation.
The case record as described in the assailed amendment included pleadings and the court’s own recital showing that the lot in controversy was actually Lot No. 1898, not Lot No. 1868.

Assailed Amendment Orders

The trial court issued an order granting respondents’ motion (filed as “Motion, dated February 25, 1996”) to amend the lot number in the dispositive portion from Lot No. 1868 to Lot No. 1898.
The motion was granted on the basis that the lot number in the dispositive portion was allegedly an error that did not conform to the pleadings, the evidence, and the prayer in the complaints.
The trial court pointed to references in paragraph 4 of the Amended Complaint dated October 16, 1967, paragraph 4 of the Third Amended Complaint dated September 23, 1971, the prayer in the Third Amended Complaint, and the court’s recital in the October 12, 1987 decision itself.
The trial court found the instant motion warranted because Lot No. 1898, Pls.-321, situated in barangay of Bagacayon, La Libertad, Negros Oriental, was the lot in controversy.
The trial court invoked the doctrine that a final and executory judgment may be amended on harmless clerical or typographical errors.
The trial court further invoked the principle that where the dispositive portion contains an ambiguity cau