Title
Camon vs. Bezore
Case
G.R. No. L-29746
Decision Date
Nov 26, 1973
Appellants claimed P64,165 from Camon's estate for sugar allotments and rentals from Hacienda Rosario. SC ruled "accrued or accruing" in Deed of Sale included all rights, dismissing claims; no express trust, implied new lease.
widow
letters of administration
estate

Case Summary (G.R. No. L-29746)

Factual Background

From crop year 1940-41 to crop year 1960-61, Emilio Camon was the lessee of Hacienda Rosario in Pontevedra, Negros Occidental. One one-half pro-indiviso of the hacienda belonged to the appellants as heirs of Thomas Fallon; the other one-half pro-indiviso belonged to Petronila Alunan vda. de Sta. Romana, Amparo Sta. Romana, and Alberta vda. de Hopon as heirs of Rosario Sta. Romana. Upon Camon’s death in 1967, Concepcion Ereneta sought and obtained letters of administration. The court ordered creditors and claimants to file demands. The appellants, through Martiniano O. de la Cruz, filed a claim for P62,065 as the money value of sugar allotments and allowances and P2,100 as the money value of palay and rentals, totaling P64,165, alleged to have been appropriated by Camon from the appellants’ half-share.

Documentary Evidence Submitted

The administratrix produced three uncontested-documents at trial: (1) an Agreement to Sell dated January 11, 1961 (exhibit "1") in which the appellants agreed to sell their one-half share to Amparo Sta. Romana and Alberta vda. de Hopon; (2) a Release and Waiver of Claims dated January 12, 1961 (exhibit "3") by which Amparo and Alberta, in consideration of services and kindnesses extended by Camon, released him from “any and all claims ... pertaining to the two-fourth pro-indiviso share ... including rights accrued or accruing,” and waived such rights in favor of Camon; and (3) a Deed of Sale dated August 4, 1961 (exhibit "2") wherein the appellants sold for P78,000 “all their rights, title, interest and participation, whether accrued or accruing in their two-fourth pro-indiviso share ... including its sugar quota,” to Amparo and Alberta.

Trial Court Proceedings and Lower Court Ruling

The Court of First Instance rejected the appellants’ contention that the sugar allotments and allowances were excluded from the sale and held that by the explicit terms of the Deed of Sale all benefits accrued and accruing to the appellants before August 4, 1961 were included in the sale. The court dismissed the appellants’ claim by order dated July 20, 1968.

Issues Presented on Appeal

The Supreme Court framed two issues: first, whether the phrase “accrued or accruing” in the deed of sale should be interpreted to exclude the sugar allotments and allowances claimed by the appellants; and second, whether the continued cultivation of the hacienda by Camon after the expiration of the written lease, in the absence of a written lease for the crop years 1952-53 to 1960-61, created an express trust in favor of the appellants.

Appellants’ Contentions

The appellants contended that the January 12, 1961 Release and Waiver could not validly release accrued claims because no sale had yet occurred and the vendees held only a promise to purchase; that the waiver was made in advance and offended public policy; that Camon was not the vendee and therefore could not have received such waiver; that the vendees represented to their judicial administrator that the sugar quedans and palay were not included in the sale; that the phrase “accrued and accruing” was obscure and should not be construed to benefit a party who caused the obscurity; that the sale consideration, approximating P1,300 per hectare, was inadequate; and that Camon’s silence in the face of demands amounted to an admission of debt. They also urged that the post-expiration continuance of Camon’s cultivation created an express trust.

Respondent’s Position and Defenses Adopted by the Lower Court

The administratrix observed that the authenticity of the documents was not contested and urged that any defect in the January 12, 1961 waiver was cured by the Deed of Sale of August 4, 1961, which expressly conveyed accrued and accruing rights, including the sugar quota, for valuable consideration. The administratrix maintained that it was immaterial that Camon was not the named vendee, since the appellants had parted with their accrued rights, and that alleged representations made to Martiniano O. de la Cruz on extrinsic intention were questions of fact not reviewable on direct appeal, citing Miguel v. Catalino, L-23072, Nov. 29, 1968, 26 SCRA 234, and Victorino v. Lao, G.R. No. L-25273, May 28, 1970, 33 SCRA 54. The administratrix further argued that the contractual phrase “accrued or accruing” was clear and governed by Art. 1370, Civil Code; that inadequacy of consideration did not invalidate the sale under Art. 1355 and precedent such as Askay v. Cosalan, 46 Phil. 179; that silence was not an evidentiary admission; and that continuance of cultivation implied a new lease under Art. 1670, Civil Code, not an express trust, while express trusts over immovables required a written instrument under Art. 1443, Civil Code.

Supreme Court’s Legal Analysis

The Court agreed that the January 12, 1961 waiver, standing alone, could not have validly released accrued claims because Amparo and Alberta at that time had only a promise from the appellants to sell and therefore lacked an existing right to waive. The Court observed the settled principle that a right must exist at the time of waiver for the waiver to be valid. Nonetheless, the Court found that any infirmity in the waiver was cured by the Deed of Sale of August 4, 1961, which expressly conveyed “rights, title, interest and participation, whether accrued or accruing,” thereby transferring the accrued claims for a valuable consideration. The Court held that it was immaterial that Camon was not the vendee named in the deed because the appellants had disposed of their accrued rights.

Interpretation of Contractual Language and Evidentiary Findings

Addressing the contention that the words “accrued or accruing” were obscure, the Court invoked Art. 1370, Civil Code, and concluded that the language was positive and categorical and required no interpretation beyond its literal meaning. The Court also held that allegations regarding the vendees’ representations to the appellants’ judicial administrator implicated factual determinations that were not reviewable in a direct appeal, relying on Miguel v. Catalino and Victorino v. Lao. The Court rejected the argument that inadequacy of price rendered the sale void, citing Art. 1355, Civil Code, and Askay v. Cosalan. The Court further found no legal basis to treat Camon’s silence as an admission in evidence.

Trust and Lease Issues

On the question whether continued cultivation after the expiration of the written lease created an express trust in favor of the owners, the Court held that continuance with the owners’ acquiescence produced, at most, an implied new lease u

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