Title
Balantakbo vs. Court of Appeals
Case
G.R. No. 108515
Decision Date
Oct 16, 1995
Dispute over land ownership: boundaries in deed prevail over area description, affirming respondent's claim to entire property.
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Case Digest (G.R. No. 108515)

Facts:

  1. Parties Involved:

    • Petitioners: Luis Balantakbo, Amadeo Balantakbo, and Heirs of Sancho Balantakbo.
    • Respondents: Court of Appeals and Laguna Agro-Industrial Coconut Cooperative, Inc. (LAGUNA).
  2. Subject Property:

    • A parcel of unregistered coconut land in Bo. Dita, Liliw, Laguna, with an area of 2,000 square meters, more or less, as described in the deed of sale.
  3. Origins of the Dispute:

    • The land was purchased by the Sumaya spouses (predecessors of LAGUNA) from Consuelo Vda. de Balantakbo (mother of petitioners) in 1955 for P800.00.
    • The sale was evidenced by a deed executed on December 13, 1955.
    • In 1975, the heirs of Consuelo (petitioners) intruded into the land and harvested coconuts, claiming ownership of a portion of the land.
  4. Stipulated Facts:

    • The parties agreed on the genuineness of certain documents, including the Deed of Extrajudicial Partition (1945) and Consuelo’s affidavit (1952).
    • The land was described as bounded by specific individuals and containing an area of 2,000 square meters, more or less.
    • LAGUNA claimed the entire land within the boundaries, while the Balantakbos argued that only 2,000 square meters were sold, leaving them with 4,870 square meters.
  5. Trial Court Decision:

    • The Regional Trial Court ruled in favor of the Balantakbos, holding that the phrase "more or less" referred only to a slight difference in area, not the 4,870 square meters claimed by the petitioners.
  6. Court of Appeals Decision:

    • The Court of Appeals reversed the trial court, ruling that the boundaries stated in the deed of sale prevail over the area described, thus declaring LAGUNA the owner of the entire land.

Issue:

The primary issue is:
In case of conflict between the area described and the actual boundaries of the land, which should prevail?

Ruling:

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the boundaries stated in the deed of sale prevail over the area described. Since the land was sold for a lump sum and not per unit of measure, the boundaries determine the scope of the sale, not the area.

Ratio:

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