Primary Holding

The Supreme Court denied the Motion for Reconsideration and Motion to Remand but granted the Motion for Clarification by rectifying specific typographical and clerical errors within its previous Decision dated February 12, 1997, ultimately granting the Petition for Review and reinstating the decision of the Court of First Instance.

Background

The case involves a land dispute where the Heirs of Navarro originally filed a Petition for Review. The Supreme Court issued a Decision on February 12, 1997, which the Heirs of Pascual found confusing, particularly the dispositive portion in relation to the body of the decision regarding the public domain nature of the land. This confusion led to the Omnibus Motion seeking clarification, reconsideration, and remand.

Facts

• 1. The Heirs of Pascual filed an Omnibus Motion arguing that the dispositive portion of the Supreme Court’s February 12, 1997 Decision, which "DENIED and DISMISSED" the Petition for Review, was inconsistent with the body of the Decision.
• 2. The Heirs of Pascual interpreted "DENIED and DISMISSED" as affirming the Intermediate Appellate Court’s decision, which would seemingly entitle them to land registration.
• 3. However, they noted that the body of the Decision declared the subject land part of the public domain, not appropriable by private persons including themselves without express authorization.
• 4. They requested clarification on whether the Decision actually reversed or affirmed the Intermediate Appellate Court and sought reconsideration and remand for further proceedings and evidence if the Decision was based on flawed findings.
• 5. The Supreme Court found typographical and clerical errors in the previous decision that needed rectification to harmonize the dispositive portion with the body.

Arguments of the Petitioners

• 1. The dispositive portion of the February 12, 1997 Decision is confusing because "DENIED and DISMISSED" implies affirmation of the Intermediate Appellate Court's decision, yet the body declares the land public domain.
• 2. The Decision should be clarified to state whether it reversed or affirmed the Intermediate Appellate Court's decision.
• 3. If the Decision reversed the Intermediate Appellate Court based on flawed findings of the Trial Court and a dissenting opinion in the appellate court, it should be reconsidered.
• 4. If more scientific or empirical data is needed, the case should be remanded to the Trial Court for further evidence.

Arguments of the Respondents

• 1. (Heirs of Navarro, as petitioners in the original petition) - N/A. The document only details the arguments of the Heirs of Pascual in their motion, and the Court's response. The perspective is from the court addressing the motion of the Pascual Heirs. The Navarro Heirs' arguments are not directly presented in this Resolution.

Issues

• 1. Whether the dispositive portion of the Supreme Court's February 12, 1997 Decision was confusing and needed clarification.
• 2. Whether the Supreme Court should reconsider its February 12, 1997 Decision.
• 3. Whether the case should be remanded to the Regional Trial Court for further proceedings and reception of evidence.
• 4. Whether there were typographical or clerical errors in the February 12, 1997 Decision requiring rectification.

Ruling

• 1. The Supreme Court found no merit in the Motion for Reconsideration and Motion to Remand.
• 2. The issues raised for reconsideration were already addressed in the original Decision.
• 3. Remand was unnecessary as the Court's findings were based on exhaustive study of facts, evidence, arguments, and law.
• 4. The Court acknowledged the need for clarification due to typographical and clerical errors.
• 5. The Court rectified specific errors: changing "We find no merit in the petition" to "We find merit in the petition," changing "petitioners" to "private respondents" in certain sections, and amending the dispositive portion from "DENIED and DISMISSED" to "GRANTED," reversing the Intermediate Appellate Court and reinstating the Court of First Instance decision.

Doctrines

• 1. N/A. This resolution primarily deals with procedural aspects of motion for clarification and reconsideration and rectification of errors, rather than invoking specific substantive legal doctrines beyond the context of land registration and public domain, which were likely discussed in the original February 12, 1997 Decision, not detailed in this resolution.

Key Excerpts

• 1. "We find no merit in the Omnibus Motion insofar as it prays for the reconsideration of our Decision dated February 12, 1997 and/or for the remand of the instant case to the Regional Trial Court for further proceedings."
• 2. "It is imperative, however, that certain typographical and/or clerical errors in the said Decision be rectified in order that the body thereof and dispositive portion therein be harmonized."

Precedents Cited

• 1. N/A. No other cases are explicitly cited in this Resolution. It is primarily focused on addressing the procedural motion and rectifying errors in its own prior decision.

Statutory and Constitutional Provisions

• 1. N/A. No specific constitutional or statutory provisions are explicitly cited in this Resolution.