Alaras v. Alaras
REITERATIONFacts
The Antecedents: Petitioners Reynaldo and Marciana Alaras, co-owners of Lot 2800, and Marciana, exclusive owner of adjacent Lot 2808, offered to sell a parcel of land to respondent Napoleon Alaras. There was a discrepancy regarding which lot was offered for sale. Napoleon Alaras, accompanied by Reynaldo, inspected the property and was shown a portion of Lot 2808, identified by Reynaldo through landmarks and tenants working on it. A Deed of Sale was later executed on September 18, 1958, referring to Lot 2800. Upon survey, Napoleon discovered the discrepancy between the land shown and the land described in the deed. Procedural History: Napoleon Alaras filed an action for specific performance, reformation of instrument, and recovery of damages. The trial court dismissed the complaint. The Court of Appeals reversed the trial court's decision, ordering the reformation of the Deed of Sale to substitute Lot 2808 (a portion thereof) for Lot 2800, and directing Napoleon Alaras to reconvey Lot 2800 back to the defendants. The Petition: Petitioners Reynaldo and Marciana Alaras filed a petition for review with the Supreme Court, essentially questioning the factual findings of the Court of Appeals regarding the identity of the land sold and the propriety of ordering reformation. They argued that the Court of Appeals erred in reversing the trial court's decision.
Issue(s)
Whether the Court of Appeals erred in ordering the reformation of the Deed of Sale. Whether the findings of fact of the Court of Appeals are binding on the Supreme Court.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The Deed of Sale was ordered to be reformed to substitute a portion of Lot 2808 for Lot 2800, and Napoleon Alaras was directed to reconvey Lot 2800 to the petitioners. Costs were taxed against the petitioners.
Ratio Decidendi
On Issue 1: Whether the Court of Appeals erred in ordering the reformation of the Deed of Sale. The Supreme Court held that the Court of Appeals did not err in ordering the reformation of the Deed of Sale. The evidence presented clearly established that the land actually shown and agreed upon by the parties was a portion of Lot 2808, not Lot 2800 as stated in the deed. Reynaldo Alaras, during the inspection, pointed out specific landmarks and tenants on Lot 2808, which were all confirmed by the tenants themselves and corroborated by a surveyor. Marciana Alaras, although not present during the initial inspection, later confirmed that the land shown by Reynaldo was indeed the property being sold. The discrepancy arose when the deed of sale was drafted, erroneously identifying Lot 2800. This situation falls squarely within the ambit of reformation of instruments, as provided for in the Civil Code, where the written instrument does not express the true intention of the parties due to mistake or fraud. The Court found that there was a mutual mistake or, at the very least, inequitable conduct on the part of the sellers in causing the deed to reflect a different property than what was identified and agreed upon. On Issue 2: Whether the findings of fact of the Court of Appeals are binding on the Supreme Court. The Supreme Court reiterated the general rule that findings of fact made by the Court of Appeals are binding upon the Supreme Court and will not be disturbed on appeal, provided that such findings are supported by substantial evidence and are not tainted with fraud, collusion, or error of law. The Court found that the present case did not fall under any of the recognized exceptions to this rule. The Court of Appeals meticulously reviewed the evidence, including the testimonies of witnesses and documentary exhibits, to arrive at its factual conclusions regarding the identity of the land sold and the circumstances surrounding the execution of the deed of sale. Therefore, the Supreme Court gave full faith and credit to the factual findings of the appellate court, which formed the basis for its decision to order the reformation of the instrument.
Main Doctrine
The Supreme Court reiterated that factual findings of the Court of Appeals are generally conclusive and not subject to review, absent any showing that the case falls under the recognized exceptions to this rule. Furthermore, the Court affirmed the availability of the remedy of reformation of an instrument when the true agreement of the parties is not expressed therein due to mistake, fraud, inequitable conduct, or accident, as provided for in Articles 1359 to 1365 of the Civil Code. The evidence presented clearly showed a discrepancy between the land identified and shown to the buyer and the land described in the deed of sale, warranting reformation.