Case Summary (G.R. No. L-22487)
Property Background and Transactions
• 1916: Eulogio Atilano I purchased Lot No. 535 in Zamboanga and obtained Transfer Certificate of Title (TCT) No. 1134.
• 1920: Lot No. 535 was subdivided into Lots 535-A through 535-E. On May 18, 1920, Eulogio I sold “Lot No. 535-E” for ₱150.00 to his brother Eulogio II, who secured TCT No. 3129. Other subdivisions were sold to third parties; Eulogio I retained what he believed to be Lot 535-A.
• May 1952: Eulogio II and his children obtained co-ownership of Lot 535-E by TCT No. 4889.
• July 1959: A resurvey revealed that the 1920 deed erroneously described as Lot 535-E the parcel actually occupied by Eulogio II (physically Lot 535-A), and that the portion held by Eulogio I (and later Ladislao) was really Lot 535-E.
Procedural History
• January 25, 1960: Heirs of Eulogio II filed in the CFI of Zamboanga seeking exchange of possession—surrender of Lot 535-A in favor of the defendants in return for Lot 535-E.
• Defendants counterclaimed for specific performance of the intended transfer of “Lot 535-E.”
• Trial court ruled for the plaintiffs solely on the ground that registered land cannot be acquired by prescription.
Applicable Law
• 1935 Philippine Constitution (property rights guarantee).
• Land Registration Act (registered titles presumed indefeasible; prescription unavailable against title).
• New Civil Code, Articles 1359 et seq. (instrument reformation for mistake, fraud, accident or inequitable conduct).
Issue
Whether the parties may correct the lot designation in the 1920 deed by executing mutual conveyances, given a mutual mistake in the lot number and continuous possession conforming to the true intention.
Court’s Analysis
- Registered titles are protected against prescription, but the controversy centers on the true intention of the 1920 sale, not adverse possession.
- The physical possession and improvements made by the brothers from 1920 onward demonstrate they dealt with specific parcels (the vendee on what proved to be Lot 535-A; the vendor on Lot 535-E),
Case Syllabus (G.R. No. L-22487)
Facts of the Case
- In 1916, Eulogio Atilano I purchased Lot No. 535 in Zamboanga from Gerardo Villanueva and obtained Transfer Certificate of Title (TCT) No. 1134.
- In 1920, he subdivided Lot 535 into five parcels: 535-A, 535-B, 535-C, 535-D, and 535-E.
- On May 18, 1920, by deed of sale for ₱150.00, Eulogio I purported to sell Lot 535-E to his brother, Eulogio Atilano II, who secured TCT No. 3129 in his name.
- Eulogio I sold lots 535-B, 535-C, and 535-D to third parties; he retained what was believed to be Lot 535-A, later passing to defendant Ladislao Atilano (TCT No. T-5056).
- Upon Eulogio II’s death, his widow and children obtained co-ownership of Lot 535-E under TCT No. 4889 (Dec. 6, 1952).
- In July 1959, a resurvey revealed that the parties had actually occupied swapped parcels: the vendee’s residence was on Lot 535-A (not E), and the vendor’s house on Lot 535-E (not A).
Procedural History
- January 25, 1960: Heirs of Eulogio II filed suit in the CFI of Zamboanga to exchange possession—offering Lot 535-A for Lot 535-E—after defendants refused.
- Plaintiffs emphasized the larger area of 2,612 sqm for Lot 535-E versus 1,808 sqm for Lot 535-A.
- Defendants counterclaimed, asserting involu