G.R. No. L-39972 - Lechugas vs. Court of Appeals

Petitioner Victoria Lechugas filed two actions in the Court of First Instance (CFI) of Iloilo:

Civil Case No. 5055 – forcible entry with damages against private respondents (Marina Loza et al.).
Civil Case No. 5303 – recovery and possession of the same property against the same respondents.

The two cases were tried jointly. The trial court dismissed both complaints. On appeal, the then CFI affirmed. The Court of Appeals (CA) likewise upheld the dismissals. Petitioner then elevated the case by petition for review to the Supreme Court.

In December 1950, petitioner contracted a private surveyor to segregate a six-hectare portion from a 12-hectare parcel owned by Leoncia Lasangue. On December 8, 1950, Leoncia executed a public Deed of Absolute Sale (Exhibit A) in favor of petitioner, describing the six hectares as Lot No. 5456 of the Lambunao Cadastre. Petitioner had the lot declared in her name under Tax Declaration No. 7912 from 1951, paid the taxes, and took actual possession through tenants.
Respondents claimed the deed actually related to Lot No. 5522 (south of the disputed parcels) and not to Lots A and B (middle and northern portions) of Lot No. 5456. They traced title on the disputed six hectares to:

Both parcels were consolidated into Lot No. 5456 at the 1959 cadastral survey and declared in the name of the heirs of Hugo Loza.

Victoria Lechugas testified to executing Exhibit A for Lots A and B, that she paid taxes and that her tenants worked the land, sharing produce.
Tenant Simeon Guinta corroborated forcible entry on June 14 and 24, 1958, when respondents entered Lots A and B with bolos, cut bamboo poles, appropriated harvests, and refused to vacate.

Leoncia Lasangue testified she sold to petitioner only the six hectares lying south of the disputed parcels (Lot No. 5522), pointing out its location. She admitted she could not read Exhibit A and signed on petitioner’s assurances.
Carmelita Loza and other witnesses detailed the chain of title to Lots A and B, confirming Lot No. 5456 belonged to the Lozas and that Lot No. 5522 was the parcel sold to petitioner.

Whether the CA erred in admitting parol evidence to vary the subject matter of Exhibit A over petitioner’s objection.
Whether respondents improperly changed their theory on appeal to assert Exhibit A described Lot No. 5522 instead of Lot No. 5456.
Whether Exhibit A could be “reformed” to reflect the true lot sold absent (a) strong, clear, convincing evidence and (b) a direct action for reformation.