Facts:

The case "Luis Asiain vs. Benjamin Jalandoni" (G.R. No. 20435, October 23, 1923) revolves around a land sale dispute. Luis Asiain, the plaintiff-appellant, owned a hacienda known as "Maria," located in La Carlota, Province of Occidental Negros, encompassing approximately 106 hectares. Benjamin Jalandoni, the defendant-appellee, owned an adjacent hacienda. In May 1920, Asiain offered to sell Jalandoni a portion of his hacienda for P55,000, indicating it contained about 25 to 30 hectares of land suitable for sugar cane cultivation, estimated to produce 2,000 piculs of sugar. Jalandoni expressed doubts about the size and yield of the land, prompting Asiain to send a letter on May 26, 1920, to reassure him of the land's worth, emphasizing that the sugar cane would yield a minimum of 2,000 piculs, and offered incentives regarding any surplus.

Subsequently, in July 1920, they met in Iloilo and executed a formal agreement detailing the sale. Despite Jalandoni

...

Facts:

Party Background and Initial Negotiations

• Luis Asiain is the owner of the hacienda known as “Maria” in La Carlota, Occidental Negros, encompassing about 106 hectares, while Benjamin Jalandoni owns an adjoining hacienda.
• In May 1920, during an encounter, Asiain expressed his willingness to sell a portion of his hacienda for P55,000, indicating roughly 25 to 30 hectares with the crop of sugar cane expected to yield not less than 2,000 piculs.
• Due to Jalandoni’s doubts about the actual land area and sugar cane yield, Asiain sent a detailed letter reaffirming his position. In the letter he:
• Reiterated his belief that the portion planted with cane contained more than 20 hectares and affirmed the quantity wager “2 against 1” to settle any differences.
• Emphasized the integrity of the transaction by stating that “we are not to deceive each other” and provided provisional sale conditions based on the progress of the cane plantation.

Formation of the Memorandum-Agreement

• In July 1920, at Iloilo, the parties prepared and executed a memorandum-agreement that:
• Described the sale of approximately 25 hectares “more or less” along with a standing sugar cane crop estimated at 2,000 piculs for a total of P55,000.
• Stipulated the payment terms as P30,000 at the signing and the remaining P25,000 within one year, with an interest rate of 10 percent on the balance.
• Provided that Asiain was responsible for caring for the plantation until the planting was complete, with any excess crop beyond 2,000 piculs belonging to him.
• Included provisions addressing mutual withdrawal: if the vendor withdrew, Jalandoni could reclaim any advanced payment plus an indemnity of P15,000; conversely, if Jalandoni withdrew, he would forfeit what had been paid.

Performance and Subsequent Developments

• After taking possession of the land, Jalandoni proceeded to have the sugar cane processed at La Carlota Sugar Central, resulting in an actual yield of 800 piculs (plus 23 cates of centrifugal sugar), which was significantly below the expected yield.
• Jalandoni later secured a certificate of title and engaged a surveyor, who found that the parcel measured only 18 hectares, 54 ares, and 22 centiares—substantially less than the approximated 25 hectares stated in the agreements.
• Payment performance was incomplete, with Jalandoni having paid the initial P30,000 and leaving a balance of P25,000 unpaid.

Legal Proceedings and Lower Court Judgment

• Luis Asiain initiated legal action in the Court of First Instance of Occidental Negros to recover the unpaid balance of P25,000 or to obtain the certificate of title and the land’s rent.
• In his counter-complaint, Jalandoni requested:
• An annulment of the contract due to the discrepancies in land area and sugar crop yield.
• That both parties return whatever they had received under the transaction.
• Damages amounting to P3,600 annually.
• Judge Eduardo Gutierrez David rendered a decision which:
• Declared null the document of purchase and its related memorandum.
• Absolved Jalandoni from paying the remaining P25,000.
• Ordered Asiain to return the P30,000 paid by Jalandoni with legal interest from July 12, 1920.
• Directed that Jalandoni turn over the tract of land and the certificate of title.
• Dismissed the counter-complaint against Asiain.

Issue:

Existence of Mutual Mistake

• Whether there was a genuine, mutual mistake by both parties regarding the actual extent of the land (actual 18+ hectares versus the stated 25 hectares “more or less”) and the sugar cane crop yield (actual 800 piculs versus the asserted 2,000 piculs).

Interpretation of the “More or Less” Clause

• Whether the phrase “more or less” in the description of the land permits only a minor tolerance in acreage or whether it fails to cover a gross discrepancy such as that observed in this case.

Application of Civil Code Provisions

• Whether the circumstances fall under Article 1471 of the Civil Code, which regulates sales for a lump sum price when land is described both by boundaries and by an estimated area.
• Whether the vendor’s obligation to deliver all land within the boundaries is fundamental, such that failure to do so (in view of the shortage) permits either a reduction in price or rescission of the contract.

Equity and Relief for Mistake

• Whether the mutual, material mistake as to the quantity and yield constitutes a ground sufficient for equitable relief, including annulment or rescission of the contract.
• Whether the court should enforce or modify the contract given the substantial deviation from the parties’ original understanding.

Impact on Payment and Obligations

• Whether the discrepancies in area and crop yield nullify the payment terms and other contractual obligations, thus justifying the refund of the amount already paid by Jalandoni.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)