Case Summary (G.R. No. 162322)
Facts
Petitioner paid the full purchase price for two registered lots and the Inocentes respondents acknowledged receipt but failed to deliver titles. On demand, respondents refused, asserting (1) the first lot’s title was held by a third party for subdivision purposes and (2) the second lot’s transfer was subject to four oral conditions never mentioned in the deeds. Petitioner sued for specific performance; respondents counterclaimed relying on those oral conditions. The trial court admitted parol evidence and dismissed both complaint and counterclaim. The Court of Appeals affirmed.
Legal Issue
Whether parol evidence may be admitted to establish oral conditions precedent to an absolute sale when the written deeds contain no reference to such conditions.
Applicable Law
Under Section 9, Rule 130 of the Rules of Court, a written agreement that constitutes the final expression of the parties’ contract excludes evidence of prior or contemporaneous oral agreements that vary its terms. Exceptions (e.g., ambiguity, fraud, mistake) must be pleaded and proved.
Supreme Court Analysis
- Reliability and Finality – Oral testimony by an interested party is less reliable than a written instrument, which “speaks with a uniform language.” The deeds of sale, absolute on their face and unambiguous, are deemed complete.
- General Rule vs. Exceptions – The deeds contain no reference to conditions precedent; the respondents did not plead any exception to the parol evidence rule (ambiguity, fraud or mistake).
- Distinguishing Precedent – Unlike in Land Settlement Development Co. v. Garcia Plantation, where the written contract expressly reserved conditions, here the deeds were “absolute” and silent on any pre-conditions.
- Burden of Pleading – Respondents failed to “squarely present” any exception; merely alleging conditions is insufficient.
- Cr
Case Syllabus (G.R. No. 162322)
Factual Background
- On September 30, 1982, respondents sold two parcels of registered land in Quezon City to petitioner for ₱35,000 and ₱20,000 respectively.
- Deed of Absolute Sale No. 1 (TCT No. 258628) describes Lot 684-G-1-B-2; consideration fully paid; sale made in favor of Rafael S. Ortanez, of legal age, Filipino, marriage under complete separation of property.
- Deed of Absolute Sale No. 2 (TCT No. 243273) describes Lot 5; consideration fully paid; same buyer particulars, resident of 942 Aurora Blvd., Cubao, Quezon City.
- Respondents received payments but did not deliver the titles; title to the first lot held by Atty. Joson for subdivision purpose, allegedly known to petitioner.
- On April 9, 1990 petitioner formally demanded delivery of both titles; respondents refused, alleging the sale of the second lot was subject to unexpressed conditions.
Procedural History
- Petitioner filed an action for specific performance in the Regional Trial Court.
- Respondents answered with counterclaim, asserting four oral conditions precedent never included in the written deeds.
- During trial, respondents introduced parol evidence of those conditions; petitioner objected under the parol evidence rule.
- The trial court admitted the oral conditions and dismissed both the complaint and counterclaim.
- The Court of Appeals affirmed the RTC decision.
- Petitioner filed a petition for review on certiorari with the Supreme Court.
Issue Presented
- Whether parol evidence is admissible to prove alleged oral conditions precedent to an absolute contract of sale when the deeds are silent on any such conditions.
Supreme Court Ruling
- The Supreme C