Title
Baguio vs. Bandal, Jr.
Case
G.R. No. 126442
Decision Date
Dec 29, 1998
RTC amended final judgment to correct clerical error, changing lot number from 1868 to 1898; SC upheld amendment, dismissing petition for lack of merit.

Case Summary (G.R. No. 126442)

Relevant Facts

The Regional Trial Court initially rendered a decision on October 12, 1987, instructing the petitioners to deliver possession of Lot 1868 to the plaintiffs and to partition the lot among the heirs of Andres Absin and others. This decision became final and executory on December 20, 1994. Subsequently, on September 12, 1995, the respondent court issued a writ of execution based on the judgment. The petitioners challenged this writ, claiming that Lot 1868 was owned by the heirs of Flavia Factoran.

Amendments to the Judgment

On February 25, 1996, the plaintiffs, through counsel, filed a motion to amend the judgment by correcting the lot number from Lot 1868 to Lot 1898, asserting that Lot 1868 was a clerical error. The court, after examining pleadings and evidence presented in previous complaints, found that the actual property under contention was indeed Lot 1898. Consequently, the court granted the motion to amend the dispositive portion of its original judgment to reflect this correction.

Legal Basis for the Court's Action

The court justified its amendment on established legal principles that allow for the correction of clerical or typographical errors in final and executory judgments. The cited cases confirmed that courts have the authority to clarify ambiguities caused by such errors, thereby ensuring that judgments accurately reflect the findings of the court. Specifically, the decisions referenced included the ruling in Vda. de Reyes vs. Court of Appeals, which supports the notion that harmless clerical errors can be rectified without infringing upon the integrity of the original ruling.

Dismissal of the Petition

The petitioners subsequently filed a motion for reconsideration regarding the court’s order to amend the judgment, which was denied on August 22, 1996. The Supreme Court, upon reviewing the case, concluded that the respondent court's actions did not constitute grave abuse of discretion. It reaffirmed that the amendments were warranted under the circumstances, confirming th

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