Conlu v. Araneta
REITERATIONFacts
The Antecedents: Plaintiffs commenced an action to recover parcels of land and damages, claiming ownership. Defendants alleged they were the owners of the disputed parcels. Procedural History: The lower court found that the plaintiffs were the owners of all parcels except for one parcel with a house thereon, which it held belonged to the estate of Vito Tiongco. The court's reasoning was based on evidence that the house was originally owned by Catalina Tiongco, left to Anselma Tiongco by will, and then Vito Tiongco was placed in possession by Anselma, who later agreed he could have it as his own if he paid P3,000. Vito Tiongco paid this sum, and subsequently claimed the property as his own, which was recognized. The Petition: Plaintiffs appealed the lower court's decision, assigning two errors: (1) allowing oral evidence to prove the ownership of the realty, and (2) declaring that Anselma Tiongco sold the realty in question to Vito Tiongco.
Issue(s)
Whether oral evidence is admissible to prove the sale of real property made in 1887. Whether the evidence adduced was sufficient to show that Anselma Tiongco sold the parcel of land and house in question to Vito Tiongco in or about the year 1887.
Ruling
The judgment of the lower court is affirmed. The Court held that the oral contract of sale was binding and valid, and the evidence was sufficient to prove the sale.
Ratio Decidendi
On the admissibility of oral evidence to prove the sale of real property: The Court held that oral contracts for the sale of real estate made prior to the enactment of the Code of Civil Procedure are binding between the parties. While Section 335 of the Code of Procedure in Civil Actions requires a written note or memorandum for the enforcement of such contracts, it does not render them invalid. The provision simply dictates the method of proof and does not go to the existence of the contract itself. Crucially, if parties to an action make no objection to the admissibility of oral evidence during the trial, they waive the provisions of the statute. In this case, the plaintiffs did not object to the thirteen witnesses who testified concerning the oral contract of sale, thereby permitting the defendants to prove the contract. Therefore, the oral contract of sale, being fully proven without objection, was binding and valid. On the sufficiency of evidence to prove the sale: The Court found that a preponderance of the evidence established that the sale of the parcel of land and house in question by Anselma Tiongco to Vito Tiongco in or about the year 1887 had indeed taken place. The lower court's finding, based on the weight of the evidence, indicated that Vito Tiongco was placed in possession of the house by Anselma, who agreed he could have it upon payment of P3,000, which he subsequently paid to her satisfaction. Although no formal conveyance was found, Vito Tiongco thereafter claimed it as his property, and it was recognized as such. Upon a full consideration of the evidence, the Supreme Court was satisfied that a large preponderance of the evidence showed the sale beyond question, and that Vito Tiongco was the owner at the time of his death.
Main Doctrine
An oral contract for the sale of real property, made prior to the enactment of the Code of Civil Procedure, is binding between the parties thereto, even if not reduced to writing, provided that no objection is made to the admissibility of oral evidence to prove the contract, which constitutes a waiver of the statutory requirement for a written note or memorandum.