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Question 8
8. Amor filed against Yoda and the Register of Deeds an action for
reconveyance, nullity of sale, and cancellation of certificate of title before
the Regional Trial Court (RTC). Amor alleged that Yoda unlawfully
obtained a certificate of title when he registered the disputed land in his
name based on a falsified deed of sale. In due course, the RTC found Amor
as the lawful owner of the realty and declared the sale void. However, the
RTC failed to expressly include in the dispositive portion the cancellation
of the certificate of title. The decision became final and executory. Amor
moved for clarificatory inquiry about the omission in the dispositive
portion. The RTC clarified its final judgment and required the Register of
Deeds to cancel the certificate of title. Aggrieved, Yoda questioned the
RTC’s course of action and argued that it cannot modify a final judgment
to correct perceived errors of law and fact. Did the RTC violate the
doctrine of immutability of final judgment when it required the
Register of Deeds to cancel the certificate of title? Explain.
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