### Facts:
The case revolves around the intestate estate of Don Antonio de Zuzuarregui, Sr., which was settled in the Court of First Instance of Rizal, Quezon City under Special Proceedings Q-325. The heirs to the estate included Antonio’s widow, Pilar Ibañez Vda. de Zuzuarregui, as the administratrix, and his children, notably Beatriz de Zuzuarregui Vda. de Reyes, Antonio Jr., Enrique, and Jose. A project of partition approved by the probate court allocated shares from the real estate, excluding Beatriz in the division of a particular parcel of land, which she exchanged for a bigger share elsewhere.
A motion to reopen the proceedings was submitted on January 29, 1973, by the administratrix and other heirs to correct a typographical error in the land description in Transfer Certificate of Title No. 42643, asserting the correct area was significantly larger than initially recorded. Despite Beatriz and her heirs’ opposition, the trial court reopened the case to correct the alleged clerical error.
### Issues:
1. Whether the correction of the property size in the estate partition constitutes a mere clerical error amendable post-judgment.
2. Whether the estate was intended to be partitioned fully and included the entire area under dispute.
3. Whether Beatriz de Zuzuarregui Vda. de Reyes was unjustly deprived of her share by the alleged fraud in the partition process.
### Court’s Decision:
The Supreme Court denied the petition for review on certiorari and affirmed the decision of the Court of Appeals and the lower court. The Court ruled that the correction of a clerical error was allowed even after a judgment had become final, provided it was due to inadvertence or negligence. The Court found that a typographical or clerical error was indeed committed in the project of partition, inadvertently misstating the area of the land in question. It reasoned that the settlement proceeding, designed to fully partition the estate, would not logically exclude a significant portion of the land. The Court also dismissed Beatriz’s claims of fraudulent concealment and injustice in the partition, highlighting that her share was not substantially less valuable compared to those of other heirs.
### Doctrine:
This case reiterates the doctrine that clerical errors or mistakes or omissions due to inadvertence or negligence in a final judgment can be corrected or supplied by the court ex parte. It emphasizes that the purpose of intestate estate proceedings is to settle the entire estate, including all properties without exception unless clearly indicated otherwise.
### Class Notes:
– **Clerical Error Correction**: Clerical or typographical errors in a judicial document can be amended even post-judgment when such errors are due to inadvertence or negligence, without altering the substantive rights of the parties involved.
– **Partition in Estate Proceedings**: The aim is to distribute all assets and properties of the deceased among the heirs, leaving no property undivided unless explicitly intended by the parties.
– **Evidence of Intent**: Repetitive documentation of erroneous information in legal documents (e.g., property area) does not automatically establish intentional fraud without clear evidence to support such a claim.
### Historical Background:
This case underscores the complexities of estate settlement, especially when clerical errors in property descriptions have significant implications for the heirs. It also highlights the judiciary’s role in rectifying such errors to fulfill the intent of equitable distribution among heirs. Judicial mechanisms for error correction thus serve as tools to uphold justice and equity, even post-judgment. This decision reflects the principle that procedural errors should not unjustly alter the substantive rights of parties in estate partitioning, reinforcing the importance of accuracy and fairness in legal documentation and proceedings.
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