Santa Ana v. Hernandez
REITERATIONFacts
1. The Antecedents: Petitioners, spouses Jose Santa Ana, Jr. and Lourdes Sto. Domingo, sold two portions of their land in Bulacan to respondent Rosa Hernandez for P11,000.00. The deed of sale described the portions with boundaries and approximate areas. Following the sale, petitioners prepared a subdivision plan, Psd-43187, which respondent refused to accept, instead preparing her own plan, Psd-42844, which indicated she occupied an area exceeding that stated in the deed of sale by approximately 17,000 square meters. Petitioners claimed this excess area was not part of the sale, while respondent asserted it was included. 2. Procedural History: The petitioners filed suit in the Court of First Instance of Bulacan, seeking to have the respondent vacate the excess area. The trial court ruled in favor of the petitioners, ordering the respondent to vacate the excess portions and confine her occupation to specific lots as per the petitioners' subdivision plan. Respondent Rosa Hernandez appealed this decision to the Court of Appeals. The Court of Appeals reversed the trial court's decision, finding that the sale was for a lump sum and applying Article 1542 of the Civil Code, declaring the respondent the owner of the entire areas within the boundaries she occupied, irrespective of the stated area in the deed. 3. The Petition: The petitioners, Jose Santa Ana, Jr. and Lourdes Sto. Domingo, filed a petition for review on certiorari with the Supreme Court, arguing that the Court of Appeals erred in departing from the trial court's findings of fact without sufficient grounds and in holding that the deed of sale was for a lump sum despite allegedly uncertain boundaries. They contended that Article 1542 of the Civil Code was inapplicable because the boundaries provided in the deed were not definite. The Supreme Court, however, affirmed the Court of Appeals' decision, holding that findings of fact by the appellate court are generally conclusive and that the sale, given the lump sum price and the approximate nature of the area stated, was a sale of a definite tract (corpus certum) where the boundaries, as found by the Court of Appeals, were sufficiently identified.
Issue(s)
Whether the Court of Appeals erred in disturbing the findings of fact of the trial court. Whether the deed of sale was for a lump sum, despite the alleged indefiniteness of the boundaries, and whether Article 1542 of the Civil Code applies. Whether the sale was made by unit of measure or for a lump sum.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, dismissing the petition. The Court held that the sale was made for a lump sum and that the properties were identified by their boundaries, thus Article 1542 of the Civil Code applies, and the respondent is entitled to all the land within the specified boundaries, regardless of the stated area.
Ratio Decidendi
On the issue of the Court of Appeals disturbing the findings of fact of the trial court: The Court reiterated that the credibility of witnesses and the weighing of conflicting evidence are within the exclusive authority of the Court of Appeals. Appellate courts are not necessarily bound by the conclusions of the trial court. The Supreme Court only reviews decisions of the Court of Appeals on questions of law, and findings of fact by the Court of Appeals are generally conclusive and not reviewable, unless they are totally devoid of support in the record or constitute a serious abuse of discretion. On the issue of whether the deed of sale was for a lump sum and the applicability of Article 1542: The Court affirmed the Court of Appeals' finding that the deed of sale was for a lump sum of P11,000.00 for both lots. The presence of the phrase "humigit kumulang" (more or less) before the stated areas further indicated that the area was approximate. The Court emphasized that for Article 1542 to apply, the sale must be for a lump sum and not at a rate per unit of measure. The Court noted that the deed of sale did not specify a price per square meter, and the notarial officer testified that the boundaries, not the stated area, would prevail. The Court found that the boundaries, including a "pilapil" or dike, were conspicuous and identified the parcels of land sold, making it a sale of a corpus certum. On the issue of whether the sale was made by unit of measure or for a lump sum: The Court held that to consider a sale as made by unit of measure, it must be clearly stated in the contract that the price is at a certain sum for each unit. In this case, the deed of sale recited a lump sum price and did not specify a price per unit of measure. The Court cited Spanish jurisprudence interpreting Article 1471 of the Spanish Civil Code (verbatim in Article 1542 of the Civil Code) which gives prevalence to the absence of a price per unit of measure over the specification of the total area, presuming that the dimensions were not essential to the parties' agreement for the lump sum price. Therefore, the sale was considered a sale for a lump sum.
Main Doctrine
In the sale of real estate for a lump sum, the boundaries of the property sold, if clearly identified, shall prevail over the stated area, even if the actual area exceeds the stated area, unless the contract explicitly states a price per unit of measure.