Case Summary (G.R. No. 196444)
Factual Background
In 2004, the petitioners entered into a contract for the sale of the aforementioned property with respondent Ingram. The contract stipulated a selling price of P1,860,000.00 for an area of approximately 6,200 square meters, as per the tax declaration. Respondent Ingram made installment payments totaling P1,715,000.00. Despite the execution of deeds of absolute sale, Ingram later discovered that the property actually measured 12,000 square meters, leading to a dispute over ownership of the excess 5,800 square meters.
Proceedings in Lower Courts
Ingram initiated a recovery case, Civil Case No. S-241, in the 3rd Municipal Circuit Trial Court (MCTC) after the petitioners contended that the excess area remained unsold. The MCTC dismissed the case due to insufficient evidence, stating that Ingram did not demonstrate her ownership of the additional area in question. The MCTC's dismissal was based on the grounds that the testimonies provided by Ingram and her witnesses contained inconsistencies.
Regional Trial Court Decision
On appeal, the Regional Trial Court (RTC) reversed the MCTC's ruling, declaring Ingram the owner of the entire property based on the sales agreement and its boundaries. The RTC determined that the area specified in the deeds and the associated boundaries were definitive, hence Ingram was entitled to the entirety of Lot No. 3230. The RTC applied Article 1542 of the Civil Code, asserting that the vendor (Arcaina) must deliver all land included within the specified boundaries, irrespective of the actual area.
Court of Appeals Ruling
The Court of Appeals (CA) affirmed the RTC's decision with modifications, excluding certain orders for the petitioners to pay attorney's fees and costs of suit. The CA reiterated that both the parties had failed to establish competent evidence indicating the true area of the property. The sale was determined to be for a lump sum rather than on a per-square-meter basis, thus aligning with the principles established in Article 1542 of the Civil Code.
Petitioners' Arguments
The petitioners sought to challenge the CA's determination, contending that the sale was on a per-square-meter basis and raised the issue of prescription under Article 1543 of the Civil Code, asserting that Ingram's action was time-barred. They also argued that the executed deeds required recognition of the unsold portion of the property, which was allegedly marked and fenced.
Supreme Court's Findings
The Supreme Court found that the actual area of Lot No. 3230 was not a disputed fact, recognizing the petitioners' judicial admission regarding the surveyed size. The Court, however, clarified that the sale was indeed for a l
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Case Overview
- This case involves a Petition for Review on Certiorari filed by petitioners Dasmariñas T. Arcaina and Magnani T. Banta against respondent Noemi L. Ingram, represented by Ma. Nenette L. Archinue.
- The petition challenges the October 26, 2010 Decision and the March 17, 2011 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 107997.
- The CA's decision modified the March 11, 2009 ruling of the Regional Trial Court (RTC) of Legazpi City, which reversed an earlier dismissal by the Municipal Circuit Trial Court (MCTC) for insufficiency of evidence.
Background of the Case
- Arcaina owned Lot No. 3230 located in Salvacion, Sto. Domingo, Albay. In 2004, her attorney-in-fact Banta entered into a contract with Ingram for the sale of this property.
- The sale contract specified the area of the lot as more or less 6,200 square meters, with a total price of P1,860,000.00, part of which was paid through installment payments.
- A Memorandum of Agreement acknowledged payments made by Ingram and stipulated a remaining balance of P145,000.00.
- Both parties executed deeds of absolute sale that described the property with specific boundaries.
Discovery of Actual Property Area
- After Ingram had the property surveyed, it was found to have an area of approximately 12,000 square meters, leading to a dispute regarding the ownership of the additional 5,800 square meters.
- Ingram claimed ownership of the entire property based on the sale, while Banta insisted that only 6,200 square m