Case Summary (G.R. No. 142345)
Factual Background
The Buayan Townsite Subdivision was owned by the Board of Liquidators, which had the property surveyed between 1948 and 1951 by Simplicio Cagampang. Subsequently, in 1954, Estrella Baterbonia acquired Lot No. 4118 and took possession of it. In 1962, Ferry Bayot acquired Lot No. 4117 from her aunt. The Board of Liquidators conducted a resurvey in 1963-1964, changing the lot numbers, although the new survey was never approved by the Bureau of Lands. Baterbonia mistakenly applied for a Miscellaneous Sales Patent for Lot No. 4117 based on the unapproved Calina survey, which was approved, granting her title to a lot that was not hers.
Judicial Proceedings and Decisions
In 1989, Bayot filed a complaint against Baterbonia for reconveyance of Lot No. 4117, claiming ownership based on her continuous possession. The trial court ruled in favor of Baterbonia, leading to an appeal to the Court of Appeals, which affirmed the trial court's decision in November 1995. Bayot's heirs later filed a Notice and Claim of Implied Trust with the Register of Deeds, asserting that Baterbonia held the property in trust for them. However, this claim was opposed by the Baterbonias, who argued that the Court of Appeals had already ruled against the existence of such trust.
Motion for Clarification
The heirs of Bayot sought clarification from the Court of Appeals concerning its 1995 decision, claiming that the court had directed Baterbonia to file a petition for the correction of her title. The Court of Appeals denied this motion, concluding that the earlier decision had become final and executory, a determination also confirmed in subsequent motions for reconsideration.
Legal Issues Presented
The primary issues for resolution included whether a final and executory decision prevents a party from filing a motion for clarification, whether the prior decision was ambiguous, and whether the respondents could be compelled to amend their title to reflect the correct property designation.
Court's Findings
The Supreme Court found merit in the petition, holding that, despite the finality of the Court of Appeals' decision, the court retains jurisdiction to clarify ambiguities arising from inadvertent omissions. The ruling explained that judgments can be amended to resolve any ambiguity, referencing past cases where this principle applies. The confusion stemmed from the lot number discrepancies created by the unapproved resurvey, impacting the rightful ownership and the ability to secure a proper title.
Direction for Amendment of Title
The Supreme Court ordered the Baterbonias
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Case Reference
- G.R. No. 142345
- Date of Decision: August 13, 2004
- Court: Supreme Court of the Philippines, Second Division
- Penning Justice: Callejo, Sr.
Parties Involved
- Petitioners: Heirs of Ferry Bayot (Simplicio Bayot, Jerry Bayot, Maricris Bayot, Teresa Obial, Rosie Palado)
- Respondents: Estrella Baterbonia and Angel Baterbonia
Nature of the Petition
- The petition is for review on certiorari against the Resolution of the Court of Appeals (CA-G.R. CV No. 44106) which denied the petitioners' motion for clarification regarding a previous decision.
Antecedents of the Case
Property Background:
- Buayan Townsite Subdivision in General Santos, Cotabato, initially owned by the Board of Liquidators.
- Surveyed by Simplicio Cagampang from 1948 to 1951, establishing lots including No. 4116, 4117, and 4118.
Acquisition of Lots:
- In 1954, Estrella Baterbonia acquired Lot No. 4118 and occupied it.
- Ferry Bayot purchased Lot No. 4117 in 1962 and took possession.
Resurvey Issues:
- A resurvey conducted by Calina Survey Office altered lot numbering, but this new survey was not approved by the Bureau of Lands.
- Baterbonia, under the belief that the resurvey was approved, filed for a Miscellaneous Sales Patent on July 6, 1966, identifying her property as Lot No. 4117.
Legal Proceedings:
- A complaint was filed by Bayot on October 30, 1989, claiming reconveyance of Lot No. 4117.
- The trial court ruled against Bayot on March 22, 1993, but directe