Manila: The Supreme Court (SC) on Friday ruled that the sale of land remains valid even if the deed of sale designates the incorrect property, provided the true agreement between the parties can be clearly demonstrated. This landmark decision allows for the correction of the deed to align with what the parties had originally agreed upon.
According to Philippines News Agency, the decision, penned by Associate Justice Henri Jean Paul B. Inting, upheld the sale of a 491-square-meter parcel of land in Cebu City to buyers Genara and Felipe Abay Sr. by sellers Crispin Caballes and the heirs of Trinidad Caballes-Gallardo. The land was part of the estate of Margarita Lopez, who had nine children, including Crispin and Trinidad. Prior to purchasing, the Abays visited the property with Crispin and Tomas Gallardo, one of Trinidad's heirs, who showed them the boundaries of the land, and later aided in building a concrete fence around it. The Abays' occupancy was disrupted when Jacinto and Chiok Ngo Lim Young's workers destroyed the fence and erected their own posts.
The Abays discovered that the Youngs had obtained a title for the property, prompting them to file a complaint with the Regional Trial Court (RTC) to annul the title. The Gallardos contested the complaint, asserting that the documentation referred to a different lot-Lot No. 6036-B, while the Abays occupied Lot No. 7. They also claimed the 1982 Extrajudicial Settlement and Sale was forged and that the 1999 Settlement and Deed of Absolute Sale, executed by Margarita's other children in favor of the Youngs, was the legitimate document.
Despite the Gallardos' and Youngs' arguments, the RTC sided with the Abays, validating the 1982 sale and criticizing the Youngs for not investigating the property's status before their purchase, especially given the existing structures. However, the Court of Appeals overturned the RTC's ruling, a decision which the SC subsequently reversed, reinstating the RTC's judgment.
The SC emphasized that under the Civil Code, inaccuracies in a written document can be rectified to reflect the parties' true agreement. The court reiterated that previous cases have supported the validity of a sale even when a deed fails to accurately describe the intended land. The SC underscored that buyers typically rely on visible property features such as boundaries and improvements rather than technical specifications or legal documents.
Ultimately, the SC concluded that the Youngs were not buyers in good faith. Given that the Abays had openly occupied and enclosed the land with a concrete fence long before 1999, a basic inspection or inquiry would have disclosed these facts. The Youngs' failure to undertake these steps invalidated their claim of good faith, affirming the Abays' prior rights to the property.
