MUNICIPALITY OF ANTIPOLO, PETITIONER, VS. AQUILINA ZAPANTA, ISIDRO DELA CRUZ, ELIAS DELA CRUZ, MARIA DELA CRUZ, MODESTA LEYVA, FERMIN LEYVA, SUSANA LEYVA, MARCIAL LEYVA, FELISA …

Municipality of Antipolo versus Zapanta

The Case

This is a land registration controversy that reached the Supreme Court as a motion for clarification of a prior decision. The Municipality of Antipolo, as petitioner, sought to correct a clerical error in the dispositive portion of the Court's earlier decision, while the private respondents, among them Aquilina Zapanta and the heirs of the Avendaño family, opposed the motion. The case matters because it illustrates the Court's power to correct a clerical error in its own judgment even after the decision has become final, and because it clarifies the scope of a decree of nullity in a land registration case, distinguishing between the titles that are voided and those that continue to be valid for practical purposes.

Procedural History

The case began as an appeal by the Municipality of Antipolo from a judgment of the then Court of First Instance of Rizal, Branch Thirteen, in a civil case. The Intermediate Appellate Court, formerly the respondent Court, issued resolutions dated August 23, 1983 and September 27, 1983. The Supreme Court, acting directly on the appeal, rendered a decision on December 26, 1984, setting aside the resolutions of the appellate court and the judgment of the Court of First Instance, and declaring null and void the judgment and decree rendered by the then Court of First Instance of Rizal, Branch Fifteen, in a land registration case, in respect of the Heirs of Joaquin Avendaño. The Municipality of Antipolo then filed a motion for clarification of paragraph three of the dispositive portion of that decision on September 16, 1986. The private respondent Aurelia Lavilla filed an opposition, the Solicitor General filed a comment, and the private respondent filed a rejoinder. The Court resolved the motion in the present resolution.

Facts

The Municipality of Antipolo filed a motion for clarification of paragraph three of the dispositive portion of the Supreme Court's decision of December 26, 1984. The motion pointed out that the dispositive portion referred to the Heirs of Isabela Avendaño, when the correct designation should be the Heirs of Joaquin Avendaño. The private respondent Aurelia Lavilla opposed the motion, and the Solicitor General submitted a comment. The private respondent also filed a rejoinder.

The Court examined the motion and the pleadings and resolved that what was involved was a mere clerical error. The Court therefore corrected paragraph three of the dispositive portion of its decision of December 26, 1984, to read Heirs of Joaquin Avendaño instead of Heirs of Isabela Avendaño. The correction was made to align the dispositive portion with the body of the decision and the true parties in interest.

The corrected dispositive portion set aside the resolutions of the appellate court and the judgment of the Court of First Instance of Rizal, Branch Thirteen, and declared null and void the judgment and decree of the Court of First Instance of Rizal, Branch Fifteen, in the land registration case, in respect of the Heirs of Joaquin Avendaño. It ordered the Register of Deeds of Rizal to cancel all certificates of title issued or transferred by virtue of that judgment and decree in respect of the Heirs of Joaquin Avendaño. It also provided that the certificate of title issued in the name of Conrado Eniceo, and transfers therefrom, by virtue of the same judgment and decree, for practical purposes shall continue to be valid.

Issues

• Whether or not the reference in paragraph three of the dispositive portion of the decision to the Heirs of Isabela Avendaño is a mere clerical error that may be corrected by the Court.
• Whether or not the correction of the clerical error may be made even after the decision has become final.
• Whether or not the certificate of title issued in the name of Conrado Eniceo, and transfers therefrom, shall continue to be valid despite the declaration of nullity of the judgment and decree in the land registration case.

Applicable Provisions

The decision does not quote any statutory provision. It rests on the Court's inherent power to correct clerical errors in its own judgments and on the principle that a clerical error may be corrected at any time, even after finality, because it does not affect the substance of the judgment. The Court's resolution is self-contained and does not cite any article or section of law.

Ruling

On the first issue, the Court held that the reference to the Heirs of Isabela Avendaño was a mere clerical error. The Court resolved to correct paragraph three of the dispositive portion of its decision of December 26, 1984, to read Heirs of Joaquin Avendaño instead of Heirs of Isabela Avendaño. The correction was necessary to make the dispositive portion conform to the body of the decision and to the true parties in interest.

On the second issue, the Court held that the correction could be made even after the decision had become final, because a clerical error is not a substantive change in the judgment. The Court acted on the motion for clarification and corrected the error without disturbing the substance of its earlier ruling.

On the third issue, the Court maintained that the certificate of title issued in the name of Conrado Eniceo, and transfers therefrom, by virtue of the judgment and decree in the land registration case, for practical purposes shall continue to be valid. The declaration of nullity was limited to the Heirs of Joaquin Avendaño, and did not affect the title of Conrado Eniceo.

Doctrine

A clerical error in a judgment may be corrected by the court at any time, even after the judgment has become final, because such correction does not affect the substance of the judgment. The correction must be consistent with the body of the decision and the true intent of the court. A declaration of nullity of a judgment and decree in a land registration case may be limited in scope, and titles issued to parties not covered by the declaration of nullity may continue to be valid for practical purposes. These principles guide the bar candidate in answering questions on the finality of judgments and the correction of clerical errors.

Disposition

The Court granted the motion for clarification and corrected paragraph three of the dispositive portion of its decision of December 26, 1984, to read Heirs of Joaquin Avendaño instead of Heirs of Isabela Avendaño, without pronouncement as to costs.

Remember This

A clerical error in a judgment may be corrected at any time, even after finality, because it does not change the substance of the ruling. Examiners use this case to test the distinction between a clerical error and a substantive amendment, and the scope of a declaration of nullity in land registration.