Case Digest (G.R. No. 108515)
Facts:
Luis Balantakbo, Amadeo Balantakbo and Heirs of Sancho Balantakbo v. Court of Appeals and Laguna Agro-Industrial Coconut Cooperative, Inc., G.R. No. 108515, October 16, 1995, the Supreme Court Second Division, Narvasa, C.J., writing for the Court.Private respondent Laguna Agro-Industrial Coconut Cooperative, Inc. (LAGUNA) (plaintiff below) filed a complaint for quieting of title against petitioners Luis Balantakbo, Amadeo Balantakbo and the heirs of Sancho Balantakbo in the Regional Trial Court (RTC), Branch 27, Sta. Cruz, Laguna (Civil Case No. SC-1367). The complaint alleged that the Sumaya spouses had purchased the subject unregistered coconut land in Barrio Dita, Liliw, Laguna, from Consuelo Vda. de Balantakbo by deed dated December 13, 1955 for P800.00, and that in 1975 the seller’s heirs intruded and harvested coconuts on the land.
The Balantakbos denied knowledge of the alleged sale and contended that the land claimed by LAGUNA was different from the parcel they owned and possessed. During trial the parties stipulated to several facts: the genuineness and due execution of an Extrajudicial Partition (Dec. 10, 1945) and Consuelo’s affidavit of self-adjudication (Nov. 3, 1952); the description of the land as having an area of 2,000 square meters “more or less” with specified boundaries; and the parties’ opposing contentions — LAGUNA’s position that the sale included the land within the stated boundaries regardless of area, and the Balantakbos’ claim that the stated boundaries actually encompassed about 6,870 sq. m. and that only 2,000 sq. m. had been sold, leaving them entitled to the remaining ~4,870 sq. m.
The RTC (Judge Francisco C. Manabat) ruled for the Balantakbos, holding that the phrase “more or less” qualified the 2,000-sq. m. figure as allowing only a slight variance and could not encompass an excess of some 4,870 sq. m., thereby dismissing LAGUNA’s complaint. On appeal the Court of Appeals, by decision promulgated July 9, 1992, reversed and declared LAGUNA owner of the entire parcel, ruling that the boundaries stated in the deed prevail over the estimated area and that a buyer acquires all land within such boundaries.
The Balantakbos brought the case to the Court by way of a petition for review on certiorari (Rule 45), questioning whether the area or the boundaries should control where they conflict. The Supreme Court considered documentary stipulations, the 1970 cadastral survey ...(Pro-only)
Issues:
- In the sale of land described by both area and specific boundaries, does the stated area or the boundaries prevail when they conflict?
- Were petitioners entitled to claim a separate parcel corresponding to the excess area revealed by later survey and...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
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