Case Summary (G.R. No. 132601)
Procedural History and Background
The petition arises from a decision of the Court of Appeals (CA) dated September 26, 2000, which reversed a prior ruling from the Regional Trial Court (RTC) of Cebu. The RTC originally awarded several parcels of land to the Caballeros, including Lot No. 11909, in a judgment rendered on February 1, 1985. The Caballeros sold this lot to Del Prado on June 11, 1990, based on a tax declaration. The final decree of registration pertaining to the properties was only issued on November 15, 1990.
Sale Agreement Details
The deed of sale for Lot No. 11909 specified that the lot was approximately 4,000 square meters and included language indicating it was sold for a lump sum of ₱40,000. Del Prado later sought registration for the entire lot under Presidential Decree (P.D.) No. 1529, arguing it was a "cuerpo cierto" sale, meaning the vendor was obligated to deliver the entire property within the specified boundaries, regardless of the stated area.
Dispute Over Sale Terms
The Caballeros opposed this petition, asserting that the sale was only for 4,000 square meters and that the understanding was not one of a lump sum. They moved to dismiss the petition, citing prescription and lack of jurisdiction. The RTC held that the sale was indeed for a lump sum and thus the entirety of Lot No. 11909 should be delivered to Del Prado.
Court of Appeals Decision
The CA reversed the RTC decision, asserting jurisdictional questions over the remedy sought by Del Prado under P.D. No. 1529 after initial registration had been accomplished. The CA concluded that the petition for registration did not constitute an appropriate legal remedy, resulting in the dismissal of Del Prado's petition.
Key Legal Issues
Del Prado raised multiple issues in her petition: (1) whether the CA made erroneous factual findings compared to the RTC; (2) whether the sale constituted a lump sum (cuerpo cierto); and (3) whether the RTC had jurisdiction over the registration petition.
Analysis of Contractual Terms
Central to the dispute is the classification of the sale. Del Prado contends the language in the deed indicates a lump sum sale, citing Article 1542 of the Civil Code, which states that for such sales, the vendor must deliver the entirety of what is included within the stated boundaries, regardless of area discrepancies. However, the Court clarified that substantial differences in area, like the discrepancy of 10,475 sq m in this case,
...continue readingCase Syllabus (G.R. No. 132601)
Case Citation and Background
- Case Reference: G.R. No. 148225
- Decision Date: March 03, 2010
- Court: Supreme Court of the Philippines, Third Division
- Petitioner: Carmen Del Prado
- Respondents: Spouses Antonio L. Caballero and Leonarda B. Caballero
- Nature of the Case: Petition for review on certiorari from the decision of the Court of Appeals dated September 26, 2000, which reversed the decision of the Regional Trial Court (RTC) of Cebu City.
Factual Background
- The RTC of Cebu City, Branch 14, adjudicated in favor of the Caballeros on February 1, 1985, in Cadastral Case No. N-6, which included several parcels of land, notably Cadastral Lot No. 11909.
- On May 21, 1987, Antonio Caballero requested the issuance of a final decree of registration for their lots.
- The RTC ordered the National Land Titles and Deeds Registration Administration to issue the decree of registration on May 25, 1987.
- The Caballeros sold Lot No. 11909 to Carmen Del Prado on June 11, 1990, based on a tax declaration, for P40,000. The sale was documented in a deed stating the property was a parcel of land situated in Guba, Cebu City.
Legal Proceedings
- Petitioner filed a "Petition for Registration of Document Under Presidential Decree (P.D.) 1529" on March 20, 1991, to have the title issued in her name covering the entire Lot No. 11909.
- The respondents opposed, asserting that only 4,000 sq m of Lot No. 11909 was sold an