Title
Supreme Court
Arcaina vs. Ingram
Case
G.R. No. 196444
Decision Date
Feb 15, 2017
Dispute over property sale: buyer claimed ownership of 12,000 sqm, but SC ruled sale was lump sum, limiting buyer to 6,200 sqm due to unreasonable discrepancy.

Case Digest (G.R. No. 198538)
Expanded Legal Reasoning Model

Facts:

  • Parties and Real Property Transaction
    • Petitioners: Dasmariñas T. Arcaina and Magnani T. Banta.
    • Respondent: Noemi L. Ingram, represented by her attorney-in-fact, Ma. Nenette L. Archinue.
    • Subject Matter: A case for recovery of ownership, possession, and damages involving Lot No. 3230, located at Salvacion, Sto. Domingo, Albay.
  • Background of the Transaction
    • Ownership and Authority
      • Arcaina is the registered owner of Lot No. 3230.
      • Banta, acting as her attorney-in-fact, entered into the contractual sale agreement with Ingram in 2004.
    • Terms and Consideration
      • The sale was based on a tax declaration which stated that the lot measured “more or less 6,200 square meters.”
      • Contract Price was fixed at ₱1,860,000.00.
      • Payments made by Ingram amounted to ₱1,715,000.00 from May 5, 2004, to February 10, 2005, leaving a balance of ₱145,000.00.
    • Documentation
      • A Memorandum of Agreement acknowledged prior payments and the outstanding balance.
      • Two deeds of absolute sale were executed, both describing the property’s boundaries and an approximate area of 6,200 sq. m. (using the qualifier “more or less”).
  • Emergence of the Dispute
    • Discovery of Discrepancy
      • A subsequent survey revealed that the actual area of Lot No. 3230 was approximately 12,000 sq. m.
      • Petitioners, relying on the survey, contended that the excess area (5,800 sq. m.) was unsold.
    • Claims and Contentions
      • Ingram claimed ownership of the entire lot based on the deeds of sale that showed the agreed area and boundaries.
      • Petitioners maintained that the transaction was limited to 6,200 sq. m., as per the tax declaration and the express writings of the deeds.
  • Procedural History and Lower Court Rulings
    • Municipal Circuit Trial Court (MCTC)
      • Ingram filed a recovery case (Civil Case No. S-241) seeking declaration of ownership, damages, attorney’s fees, and a preliminary injunction.
      • The MCTC dismissed the complaint for insufficiency of evidence; it found inconsistencies in witness testimonies and determined that only 6,200 sq. m. was sold.
      • An order was rendered dismissing Ingram’s claim and awarding petitioners a counterclaim for the balance of ₱145,000.00.
    • Regional Trial Court (RTC)
      • The RTC reversed the MCTC’s decision, setting aside the dismissal.
      • It declared Ingram the owner of the whole lot, ordering petitioners to deliver the property and to pay the outstanding balance plus attorney’s fees and costs.
      • The RTC based its ruling, in part, on Article 1542 of the Civil Code, noting that the sale was a lump sum transaction.
    • Court of Appeals (CA)
      • The CA affirmed the RTC ruling with modifications, specifically deleting the award for attorney’s fees and litigation costs.
      • It supported the conclusion that no evidence established the property’s actual area as 12,000 sq. m., relying instead on the written deeds and the presumption of public record.
  • Additional Factual Clarifications and Arguments
    • Discrepancies in Evidence
      • Both parties relied on different evidentiary bases: Ingram on the deeds of sale indicating the boundaries and area, and petitioners on the survey results and subsequent admissions.
      • Judicial admissions during trial confirmed that the property was surveyed at approximately 12,000 sq. m.
    • Contrasting Interpretations
      • Petitioners argued that the sale was on a per-square-meter basis at ₱300.00 per sq. m. and that they were aware of the excess area.
      • Ingram maintained that the contractual intent was the sale of the entire property as defined by the written documents, that is, a lump sum sale covering 6,200 sq. m.

Issues:

  • Nature of the Sale Agreement
    • Was the sale of Lot No. 3230 a lump sum transaction or a per-square-meter contract?
    • What was the true intent of the parties regarding the extent of the property sold?
  • Interpretation of Contractual Descriptions
    • How should the qualifier “more or less” in describing the area (6,200 sq. m.) be interpreted?
    • Does this language extend to cover a substantial discrepancy (an excess of 5,800 sq. m.)?
  • Application of Relevant Civil Code Provisions
    • Should Article 1542 (governing lump sum sales) or Article 1539 (governing unit price contracts) apply?
    • What are the implications of applying either article to this case?
  • Evidentiary Value of Judicial Admissions and Survey Results
    • Are the judicial admissions regarding the property’s surveyed area (approximately 12,000 sq. m.) conclusive?
    • Can extrinsic evidence override the written stipulations of the deeds of sale?
  • Timeliness and Prescription
    • Does the claim fall within the prescribed period under Article 1543 of the Civil Code?
    • Is the issue of prescription properly raised, given that Ingram’s intention was not to rescind the sale but to recover the excess area?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.