L-22487, May 21, 1969
Topics:
Reformation of Instruments
Doctrines:
Reformation of the instrument is the solution in cases where there is a straightforward error in the document’s drafting that misidentifies the property being sold as the sale’s object, demonstrating that the parties to the contract have come to an understanding.
Summary:
Lot No. 535 was acquired by Eulogio Atilano I (Eulogio I) from Gerardo Villanueva. He divided the land into five sections (535-A, 535-B, 535-C, 535-D, and 535-E). With regard to 535-E, Eulogio I executed a deed of sale in favor of his brother Eulogio Atilano II (Eulogio II), who in his name acquired CTC No. 3129. Sale of 535-B, 535-C, and 535-D to third parties. The 535-A is kept for Eulogio I. When Eulogio I passed away, Ladislao Atilano received 535-D together with TCT No. T-5056. TCT No. 4489 was gained by Eulogio II and his offspring over Lot 535-E, they shared ownership of this property. The defendants claimed that the interchange of Lots 535-A and 535-E was an unintentional mistake, that the parties to the sale intended to deliver the lot correctly as Lot 535-A, and that Eulogio I had owned the 535-E section since Lot 535 as a whole was sold until his passing.
Facts:
Lot No. 535 was acquired by Eulogio Atilano I (Eulogio I) from Gerardo Villanueva. He divided the land into five sections (535-A, 535-B, 535-C, 535-D, and 535-E). With regard to 535-E, Eulogio I executed a deed of sale in favor of his brother Eulogio Atilano II (Eulogio II), who in his name acquired CTC No. 3129. Sale of 535-B, 535-C, and 535-D to third parties. The 535-A is kept for Eulogio I. When Eulogio I passed away, Ladislao Atilano received 535-D together with TCT No. T-5056. TCT No. 4489 was gained by Eulogio II and his offspring over Lot 535-E, they shared ownership of this property. They made the decision to dissolve the co-ownership and divide Lot 535-E. But they soon discovered that they were actually occupying lot 535-A, not 535-A, which was the land that Eulogio I had kept.
Eulogio II passed away, and his heirs brought a claim in the CFI, saying that they offered to turn up to the defendants Lot 535-A and Lot 535-E and demanded that they be delivered to Eulogio II’s heirs, but the defendants resisted.
The defendants claimed that the interchange of Lots 535-A and 535-E was an unintentional mistake, that the parties to the sale intended to deliver the lot correctly as Lot 535-A, and that Eulogio I had owned the 535-E section since Lot 535 as a whole was sold until his passing.
Issue:
Which Eulogio I or Eulogio II’s successors are the owners of Lot 535-E?
Ruling:
Eulogio I. The subject of the sale, as intended and understood by the parties, was that particular portion where the Vendee (Luisa Bautista and Eulogio II) was already residing at the time of the sale, where he rebuilt his home at the end of the war, and where his heirs, the plaintiffs in this case, continued to reside thereafter: lot No. 535-A; and that its designation as lot No. 535-E in the deed. The new Civil Code offers reformation of the instrument as a remedy for such a situation. This remedy is available when, after a meeting of the minds of the parties to a contract, their true intention is not expressed in the document claiming to embody the agreement due to error, fraud, unjust conduct, or accident (Art. 1359, et seq.). In this situation, the deed of sale signed in 1920 does not need to be reformed. The only thing that needs to be done is for the parties to execute mutual deeds of transfer because they have maintained ownership of their respective properties in accordance with the sale’s true objective.