Title
Sta. Ana, Jr. vs. Herdez
Case
G.R. No. L-16394
Decision Date
Dec 17, 1966
Land sale dispute: lump sum payment vs. unit measure; boundaries in deed deemed definite; excess area awarded to buyer per Civil Code Art. 1542.
land dispute
sale of land
boundaries
A

Case Summary (G.R. No. L-16394)

Factual Background

The petitioners sold to respondent two portions of their property on 28 May 1954, for P11,000.00. The deeds of sale described the sold portions by reference to boundary markers and included areas stated with the qualification “humiguit kumulang” (more or less). One deed described a portion “bahaguing nasa gawing Hilagaan” with “(12,500), m.c. humiguit kumulang” and boundary references to named persons and adjacent land interests. The other portion was described “bahaguing nasa gawing Silanganan” with “(26,500) metros cuadrados, humiguit kumulang” and boundary references to adjacent land and roads.

The petitioners later caused the preparation and approval of a subdivision plan for the entire land, resulting in plan Psd-43187, approved on 13 January 1955. Respondent, unlike prior vendees, refused to conform to that plan and refused to execute an agreement for subdivision and partition registration. Respondent instead caused a different subdivision plan that matched the areas she actually occupied, which was approved by the Director of Lands on 24 February 1955 as Psd-42844.

Upon that divergence, on 28 February 1955, the petitioners filed suit against respondent in the Court of First Instance of Bulacan, alleging that respondent was occupying an excess of 17,000 square meters over what she purchased. Respondent countered that the “excess” formed part of what she bought. The trial court ultimately treated the dispute as one over whether the sale was of portions with “clear boundaries but with exact areas,” as petitioners asserted, or whether it was of portions with definitive boundaries where the boundaries, not the stated areas, controlled.

Trial Court Proceedings

The trial court framed the issue as whether the petitioners “had sold two portions without clear boundaries but with exact areas (twelve thousand five hundred square meters and twenty-six thousand square meters) at the rate of P0.29 per square meter, or” whether, as respondent contended, the sold portions “were not definite but which were well defined on the land and with definite boundaries and sold for the lump sum of P11,000.00.”

The Court of First Instance ruled for petitioners. It ordered respondent, among other things, to vacate the excess portions actually occupied and to confine her occupation only to Lots 4-a and 4-b as shown in Psd-43187 (Exhibit E referred to in the decision).

The Parties’ Contentions

Respondent appealed to the Court of Appeals, which dismissed the petitioners’ complaint. On appeal before the Supreme Court, petitioners assigned errors largely directed at two points: first, that the Court of Appeals wrongly disturbed the trial court’s factual findings; and second, that the Court of Appeals wrongly held that the deed of sale embodied a lump-sum sale despite petitioners’ claims that the deed’s boundary descriptions were insufficiently certain, thereby purportedly defeating the application of Article 1542.

Petitioners relied on the rule that appellate courts should not substitute their factual findings for those of the trial court absent strong and cogent reasons. On the legal point, petitioners argued that Article 1542 should not govern because the boundaries in the deed were allegedly indefinite.

Decision of the Court of Appeals

The Court of Appeals treated the transaction as a sale of a defined tract identified by boundaries, for a single lump sum. It found that the deed of sale provided for the sale of two separate portions for the single consideration of P11,000.00. It rejected petitioners’ claim that the sale was made “by a unit of measure or per square meter,” and it also discredited the notarial officer’s failure to corroborate petitioners’ interpretation of the stated purchase price calculation.

The Court of Appeals anchored its factual conclusion on testimony regarding the notarial officer’s account and on the circumstance that respondent complained of the stated areas being less than the actual areas. It also noted that the prior conveyances by petitioners for other portions were for lump sums and that witness testimony supported the view that the parties treated the parcels as identified by prominent boundary features.

The Court of Appeals emphasized that the parcels were separated from the rest of the property by a long and continuous “pilapil” or dike, and it treated as persuasive the evidence relating to the occupation and tenancy patterns on the larger and smaller parcels. From these facts, it concluded that the sold parcels were identified by conspicuous boundaries. It then applied Article 1542 to hold that, since the sale was for a lump sum and not “at the rate of a certain sum for a unit of measure,” the buyer could not demand an adjustment of price due to greater or lesser area.

Consequently, the Court of Appeals declared respondent the owner of the whole of Lots 4-a and 4-b reflected in respondent’s subdivision plan Psd-42844, despite the increased area compared to what was stated in the deeds.

Issues Before the Supreme Court

The Supreme Court confronted two principal matters. The first was whether the Court of Appeals committed reversible error by departing from the trial court’s findings of fact on conflicting testimony. The second was whether the Court of Appeals correctly applied Article 1542, which turns on whether the sale was for a lump sum of a defined tract (“a corpo cierto”) or whether it was a sale “at the rate of a certain sum for a unit of measure,” in which case changes in area may affect price.

Legal Reasoning on Review of Facts

On the first assignment of error, the Supreme Court held that credibility determinations and weighing of conflicting evidence are matters within the exclusive authority of the Court of Appeals. It explained that R.A. 296, section 29 and Rule 45, section 2 permit review of Court of Appeals decisions on questions of law only. It also reiterated that findings of fact by the Court of Appeals are conclusive and are not reviewable by the Supreme Court, absent a showing that the findings are totally devoid of support in the record or so glaringly erroneous as to constitute serious abuse of discretion.

Applying those standards, the Supreme Court rejected petitioners’ argument that the Court of Appeals improperly substituted its own factual conclusions. It stated that it was not expected or required to examine and contrast the oral and documentary evidence submitted by the parties when the Court of Appeals’ factual findings stand on the record.

Legal Reasoning on Article 1542 and the Nature of the Sale

On the second assignment of error, the Supreme Court first acknowledged that the deed of sale recited a lump-sum price of P11,000.00 for both lots. Petitioners nonetheless insisted that the areas stated should control and contended that the boundaries were indefinite because the southern boundary of the small parcel and the western boundary of the larger parcel were described only as “lupang kasanib” and “lupang kasanib (Jose Sta. Ana, Jr.).”

The Supreme Court, however, relied on the Court of Appeals’ factual determination that the two parcels were identified by conspicuous boundaries. It accepted this factual finding because it could not be questioned at that stage. The Court reasoned that a sale of a defined and identified tract, a corpus certum, obliges the vendors to deliver all land included within the boundaries, regardless of whether the real area is greater or smaller than the area stated in the deed. It supported this proposition with the cited jurisprudence that treats boundaries as controlling in “corpus certum” sales.

The Court further stressed that the areas stated in the deed were qualified as approximate—“humiguit kumulang” (more or less). In that setting, it explained that holding the buyer to no more than the recited area would require clarity that the sale was made by the meter at a definite price for each unit. It invoked the rule that if the defendant intended to

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