Case Digest (G.R. No. 20435)
Facts:
In Luis Asiain vs. Benjamin Jalandoni, decided October 23, 1923, Luis Asiain, owner of the 106-hectare Hacienda “Maria” in La Carlota, Occidental Negros, agreed in May 1920 to sell a tract he gestured to as “between 25 and 30 hectares” with an estimated crop of 2,000 piculs of sugar for P55,000 to his neighbor Benjamin Jalandoni. Asiain confirmed in a May 26, 1920 letter that the land “contains more than 20 hectares” and warranted the 2,000-picul yield, offering to make up any shortfall in sugar and to keep any surplus. In July 1920 the parties signed a detailed memorandum fixing the sale at “25 hectares more or less,” describing boundaries, payment terms (P30,000 down, P25,000 within a year at 10% interest), and vendor obligations regarding cultivation and surplus. On July 12, 1920 they executed a binding agreement providing for partial payment receipts, mutual penalties for withdrawal, and “more or less” language qualifying quantity. Jalandoni paid P30,000, took possession, miCase Digest (G.R. No. 20435)
Facts:
- Parties and land
- Luis Asiain—owner of Hacienda “Maria” (~106 hectares) in La Carlota, Occidental Negros.
- Benjamin Jalandoni—owner of an adjoining hacienda.
- Negotiations and agreements
- May 1920 oral discussions: Asiain offers P55,000 for a tract “between 25 and 30 hectares” with a sugar-cane crop producing not less than 2,000 piculs of sugar.
- Letter dated May 26, 1920: Asiain assures Jalandoni the tract planted with cane contains over 20 hectares, warrants 2,000 piculs of sugar (deficiency made up in sugar; excess belongs to vendor).
- July 12, 1920 agreements:
- Memorandum—sale of “25 hectares more or less” plus crop for P55,000; payment of P30,000 at signing and P25,000 within one year at 10% interest; vendor to cultivate until planting; excess crop to vendor; boundaries described.
- Formal agreement—recites P55,000 purchase price; vendor may collect advances; vendor’s withdrawal penalized by P15,000; purchaser’s withdrawal forfeits advances.
- Post-contract events and dispute
- Jalandoni mills the cane—yields only about 800 piculs; survey shows area is 18 ha 54 a 22 ca.
- Of P55,000, P30,000 was paid; P25,000 remains unpaid.
- Asiain sues for the balance or to recover title and rents; Jalandoni counterclaims for annulment, return of advances, and P3,600 annual damages.
Issues:
- Is the lump-sum sale enforceable despite substantial deficiency in area and crop?
- Does Civil Code article 1471, governing sale with area designation and boundaries, apply?
- Does a mutual, material mistake as to land quantity and crop permit rescission or require price adjustment?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)