In Veronica Roble, Lilibeth R. Portugaliza, and Bobby Portugaliza vs. Dominador Arbasa and Adelaida Arbasa, the Supreme Court clarified the extent of land conveyed in a sale, especially when the deed of sale describes the property by its boundaries rather than precise measurements. The Court ruled that a significant discrepancy between the area stated in the contract and the actual area possessed does not automatically entitle the buyer to the excess, particularly when the additional land was reclaimed and not part of the original sale. This decision underscores the importance of clearly defined boundaries and a reasonable interpretation of the phrase ‘more or less’ in real estate transactions. Understanding this ruling helps prevent disputes over land ownership, ensuring clarity and fairness in property dealings.

From Seashore to Dispute: Who Owns the Reclaimed Land?

The heart of this case lies in a land dispute in Isabel, Leyte. In 1976, Dominador and Adelaida Arbasa (respondents) purchased a parcel of land from Fidela Roble, described as having an area of 240 square meters. Over time, the respondents reclaimed a portion of the sea adjacent to their property, expanding the land to 884 square meters. After Fidela Roble passed away, her nieces Veronica and Lilibeth Roble (petitioners) claimed ownership of the reclaimed portion. This claim led to a legal battle over who rightfully owned the additional 644 square meters. The Supreme Court was tasked with determining whether the original sale included the subsequently reclaimed land, examining the implications of boundary descriptions in property transactions.

The trial court initially sided with the petitioners, asserting that the deed of sale only covered the original 240 square meters. The Court of Appeals, however, reversed this decision, declaring the respondents as the lawful owners of the entire 884 square meters. The appellate court reasoned that because the deed described the property as bounded by the seashore, any subsequent reclamation should accrue to the benefit of the respondents. This ruling prompted the petitioners to elevate the case to the Supreme Court, questioning the interpretation of the deed of sale and the implications for land ownership in cases involving reclaimed areas.

The Supreme Court, in its analysis, emphasized the distinction between a sale of cuerpo cierto (lump sum sale) and a sale by unit of measure. In a cuerpo cierto sale, the vendor is obligated to deliver everything within the specified boundaries, regardless of the actual area. However, this rule is not absolute. The Court acknowledged that the use of ‘more or less’ in designating quantity covers only a reasonable excess or deficiency. According to Article 1542 of the Civil Code of the Philippines:

“In the sale of real estate, made for a lump sum and not at the rate of a certain sum for a unit of measure or number, there shall be no increase or decrease of the price although there be a greater or lesser area or number than that stated in the contract.”

In this context, the Supreme Court deemed an additional 644 square meters as an unreasonable excess beyond the contemplation of the parties at the time of the sale. The Court noted the original agreement described the property as having an ‘approximate area of 240 square meters more or less’. The discrepancy between 240 square meters and the claimed 884 square meters was deemed far too substantial to fall within the scope of ‘more or less’.

Building on this principle, the Court examined the circumstances surrounding the sale. It was established that, at the time of the transaction, only the 240 square meters existed. The rest was foreshore land, which was not alienable and disposable at the time. The Court highlighted that the respondents themselves acknowledged that the additional land was reclaimed after the sale. Adelaida confirmed that the houses of Fidela and Gualberto were constructed on what was still foreshore land, adjacent to the 240 square meter property she purchased.

The Supreme Court emphasized the importance of adhering to the parol evidence rule, which generally prohibits the introduction of extrinsic evidence to vary the terms of a written agreement. According to Rule 130, Section 9 of the Rules of Court, when the terms of an agreement have been reduced to writing, it is considered as containing all the terms agreed upon. Therefore, no evidence of such terms may be presented other than the contents of the written agreement itself. The Court found no ambiguity in the deed of sale and thus upheld its literal interpretation.

The Court referenced jurisprudence that sale is a consensual contract perfected by mere consent. The essential elements of a contract of sale are (a) consent or meeting of the minds, that is consent to transfer ownership in exchange for the price; (b) determinate subject matter; and (c) price certain in money or its equivalent. All these elements were present in the instant case. The Court noted that the terms of the contract were clear and left no room for doubt, reinforcing the principle that contracts are the law between the contracting parties.

Moreover, the Court also considered the nature of the additional 644 square meters of land. Even though the respondents claimed they were responsible for reclaiming the portion, there was no evidence they subsequently filed an application for lease with regard to the reclaimed land. Foreshore land, as part of the alienable land of the public domain, may only be disposed of by lease and not otherwise. Therefore, the Court remanded the case to the trial court to determine whether the lands subject of the action for quieting of title are foreshore lands.

FAQs

What was the key issue in this case?	The main issue was to determine the extent of the property sold in a deed of sale, specifically whether it included a significantly larger reclaimed area adjacent to the originally described land. The Supreme Court had to decide if the phrase ‘more or less’ could reasonably encompass such a substantial difference in land area.
What is a sale of ‘cuerpo cierto’?	A sale of ‘cuerpo cierto’ or lump sum is a transaction where a property is sold in its entirety for a single price, rather than based on a per-unit measurement. The vendor is obligated to deliver everything within the boundaries specified in the contract, regardless of minor discrepancies in the actual area.
What is the parol evidence rule?	The parol evidence rule states that when an agreement has been put in writing, the written document is considered the complete and final agreement. Extrinsic evidence, such as oral agreements or prior negotiations, cannot be used to contradict, vary, or add to the terms of the written contract.
What is foreshore land?	Foreshore land is the strip of land between the high and low water marks that is alternately wet and dry due to tidal flow. Under Philippine law, foreshore land is part of the public domain and can only be disposed of through lease agreements, not through sale.
What does ‘more or less’ mean in a land sale contract?	The phrase ‘more or less’ in a land sale contract allows for reasonable variations in the stated area due to minor inaccuracies in measurement. However, it does not justify significant discrepancies that would fundamentally alter the agreed-upon terms of the sale.
Why was the case remanded to the trial court?	The case was remanded to the trial court for a determination of whether the disputed 644 square meters of land constituted foreshore land. This classification is crucial because foreshore land is governed by specific laws regarding its use and disposition.
What was the Court of Appeals’ initial decision?	The Court of Appeals initially ruled in favor of the respondents, stating that they were entitled to the entire 884 square meters of land because the original deed described the property as bounded by the seashore. The Supreme Court reversed this decision.
What was the basis for the Supreme Court’s decision?	The Supreme Court based its decision on the principle that the ‘more or less’ clause in the deed of sale could not reasonably encompass an additional 644 square meters, especially since that portion was reclaimed after the sale. The Court also considered that the respondents did not have a lease for the reclaimed land.

This case underscores the importance of clearly defining the boundaries and extent of land being sold. It also highlights the limitations of relying on general descriptions or phrases like ‘more or less’ when significant discrepancies exist. Furthermore, the decision reaffirms the state’s control over foreshore lands, emphasizing the need for proper legal processes when dealing with reclaimed areas.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: VERONICA ROBLE VS. DOMINADOR ARBASA, G.R. No. 130707, July 31, 2001