Facts:

The case involves Miguel Semira as the petitioner and Buenaventura An as the respondent, with the decision rendered by the Supreme Court on March 2, 1994. The dispute centers around a parcel of land designated as Lot 4221, originally owned by Juana Gutierrez, who sold it to Buenaventura An for P850.00 on January 4, 1961. The deed of sale specified the area as approximately 822.5 square meters and detailed the boundaries of the property. Following the sale, An occupied the land according to the stated boundaries. In 1964, An acquired an adjacent parcel, Lot 4215, from the spouses Pascual Hornilla and Gliceria Ilao. On October 18, 1972, An sold Lot 4221 to his nephew, Cipriano Ramirez, for P2,500.00, with the same area and boundaries, except for the eastern boundary, which was updated to reflect An's ownership of Lot 4215.

In 1979, Ramirez sold Lot 4221 to Semira for P20,000.00, but the deed stated the area as 2,200 square meters, which was confirmed by a cadastral surve...

Facts:

Ownership and Sale of Lot 4221

• Juana Gutierrez owned a parcel of land, Lot 4221, in Sto. Nino, Taysan, Batangas.
• On January 4, 1961, she sold Lot 4221 to Buenaventura An for P850.00 through a "Kasulatan ng Bilihan ng Lupa."
• The deed stated the lot's estimated area as 822.5 square meters and described its boundaries.

Subsequent Transactions

• Buenaventura An later acquired two adjacent parcels of land: Lot 4215 (8,606 square meters) from the Hornilla spouses on June 30, 1964, and another lot (11,000 square meters) from Santiago Asi.
• On October 18, 1972, Buenaventura An sold Lot 4221 to his nephew, Cipriano Ramirez, for P2,500.00. The deed retained the same boundaries but updated the eastern boundary to reflect Buenaventura An's ownership of Lot 4215.

Transfer to Miguel Semira

• On March 12, 1979, Cipriano Ramirez sold Lot 4221 to Miguel Semira for P20,000.00. The deed now stated the area as 2,200 square meters, based on a 1974 cadastral survey.
• Semira entered the property and began constructing a rice mill on March 17, 1979.

Dispute Over Land Area

• Buenaventura An filed a forcible entry complaint against Semira on April 18, 1979, claiming Semira occupied 1,377 square meters of Lot 4215, which An had acquired in 1964.
• Semira denied the allegations, asserting ownership of the entire 2,200 square meters of Lot 4221 based on the 1979 deed of sale.

Procedural History

• The Municipal Circuit Trial Court (MCTC) initially dismissed the case for lack of jurisdiction but later ruled in favor of Semira, recognizing his ownership and possession of the disputed area.
• The Regional Trial Court (RTC) reversed the MCTC, ruling that Buenaventura An had prior possession since 1964 and that Semira forcibly occupied the land.
• The Court of Appeals affirmed the RTC decision.

Issue:

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Ruling:

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Ratio:

1. Boundaries Over Area in Lump Sum Sales: When land is sold for a lump sum, the boundaries stated in the contract determine the scope of the sale, not the area. The vendor is obligated to deliver all land within the boundaries, even if the actual area exceeds the stated size.
2. Ownership and Possession Intertwined: In this case, resolving the issue of prior possession required determining ownership. The disputed portion's inclusion in Lot 4221 or Lot 4215 depended on ownership, which was central to the case.
3. Forcible Entry Requires Prior Possession: Buenaventura An failed to prove prior physical possession of the disputed area, a necessary element for a forcible entry claim.
4. Provisional Nature of Ownership Determination: The Court's decision on ownership was provisional and limited to resolving the forcible entry case. It does not bar a separate action to determine title to the land.

Conclusion:

The Supreme Court ruled in favor of Miguel Semira, reinstating the MCTC's decision and holding that the boundaries, not the area, governed the sale of Lot 4221. Buenaventura An's forcible entry claim failed due to his inability to prove prior possession.