Case Digest (G.R. No. 133643)
Facts:
Rita Sarming, et al. v. Cresencio Dy, et al., G.R. No. 133643, June 06, 2002, the Supreme Court Second Division, Quisumbing, J., writing for the Court.Petitioners are the successors-in-interest of the original defendant Silveria Flores; respondents are the successors-in-interest of the original plaintiffs, including Alejandra Delfino, who bought one of the lots; other parties are successors of various Flores relatives who claimed ownership interests in the lands involved. The dispute concerns two adjacent parcels in Dumaguete City: Lot 5734 (OCT No. 4918‑A) and Lot 4163 (OCT No. 3129‑A). After the death of their ancestor, siblings Jose, Venancio and Silveria Flores occupied and thereafter transmitted possession of Lot 5734 and Lot 4163 in differing shares among heirs.
In January 1956, heirs of Jose (Luisa, Trinidad, Ruperto and Tomasa) agreed to sell their one‑half share of Lot 4163 to Alejandra Delfino; Silveria declined to sell her share but did not object to the transaction. At a conference before the notarization of the sale, Silveria, through her daughter, delivered OCT No. 4918‑A (Lot 5734) instead of the title to Lot 4163; believing the title matched the parcel described to them, the parties executed a notarized Settlement of Estate and Sale dated January 19, 1956. A new TCT No. 5078 was issued in the names of Silveria and Alejandra, each holding one‑half. Alejandra immediately took possession and improved the parcel actually occupied (the eastern half of Lot 4163).
When Alejandra later sought to buy an adjoining portion, she discovered the deed misidentified the lot as Lot 5734. Attempts to obtain the correct title from Silveria failed, prompting Alejandra and the vendors to sue Silveria for reformation of instrument with damages before the Regional Trial Court (Branch 41), Dumaguete City (Civil Case No. 3457). Silveria answered asserting sole ownership of Lot 4163 and that the deed recited the sale of Lot 5734; she sought declaration of sole ownership and possession and counterclaims for damages.
The trial court after evidentiary proceedings (including a spot survey and multiple substitutions of parties, and despite loss/reconstitution of some records due to fire) ruled in favor of the plaintiffs on September 29, 1992, ordering among other things the reformation or mutual conveyance to give Alejandra (and heirs) one‑half of Lot 4163, and awarding P5,000 actual damages, P10,000 moral damages and P2,000 attorneys’ fees. The Court of Appeals, in CA‑G.R. CV No. 39401, affirmed the trial court’s decision by its September 23, 1997 decision. Petitioners filed a motion for reconsideration which was denied...(Subscriber-Only)
Issues:
- Is there a cause of action for reformation of instrument against Silveria Flores and her successors‑in‑interest?
- Is reformation of the Settlement of Estate and Sale proper because the instrument mistakenly designated Lot 5734 instead of Lot 4163?
- Are the heirs of Alejandra Delfino entitled to actual and moral da...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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