In Gil Macalino, Jr. vs. Artemio Pis-An, the Supreme Court clarified that in disputes over property ownership, the true intent of the parties involved, as evidenced by their actions and testimonies, takes precedence over a strict, literal interpretation of written deeds. The Court ruled that Artemio Pis-An was the rightful owner of a specific lot, despite claims by Gil Macalino, Jr., who argued that ambiguous wording in prior sale documents entitled him to the land. This decision underscores the importance of examining the conduct of parties to discern their actual agreement, especially when written documents are unclear. Practically, this means that property disputes may hinge more on demonstrating what parties understood and intended, rather than just what the documents state on their face.

Roadblocks and Realities: Did a Land Sale Extend Beyond the Pavement?

This case revolves around a parcel of land in Dumaguete City originally owned by Emeterio Jumento. After a barangay road bisected the property, disputes arose regarding the ownership of the resulting lots. The central question is whether Gil Macalino, Jr., through a series of sales, acquired rights to a lot across the road from the property he initially purchased, or if the sale was limited to the specific area described in his deed.

The factual backdrop involves an Original Certificate of Title (OCT) No. 2393-A under which Emeterio Jumento owned a portion of Lot 3154, with the remainder belonging to his children. Upon their death, Emeterio inherited the entire lot. Subsequently, a barangay road was constructed across the property, dividing it into three sections: Lot 3154-A, Lot 3154-B (the road itself), and Lot 3154-C. Artemio Pis-an, a grandson-in-law of Emeterio, later commissioned a survey to reassess property taxes on the remaining private portions.

In 1995, Artemio and the other heirs of Emeterio executed an Extra Judicial Settlement of Estate and Absolute Sale, selling a 207-square meter portion of Lot 3154 to the spouses Wilfredo and Judith Sillero. However, the document did not specify which portion was being sold, only stating it was a 207-square meter area of the described parcel. After the sale, the spouses Sillero fenced Lot No. 3154-A and built a house. Then, they sold it to Gil Macalino, Jr. via a Deed of Sale in 1996, identifying the property as Sub-lot 3154-A. This deed mentioned that the whole Lot 3154 was covered by Original Certificate of Title No. 2393-A.

Later, intending to register Lot 3154-A, Gil commissioned a survey and discovered the area was only 140 square meters, not 207. Believing he was deceived, Gil filed estafa charges against the spouses Sillero. Following this, a Subdivision Plan was approved in 2001, dividing Lot 3154 into four sub-lots: Lot 3154-A (140 sq. m.), Lot 3154-B (the road, 215 sq. m.), Lot 3154-C (67 sq. m.), and Lot 3154-D (47 sq. m.). The plan identified both Lot 3154-A and Lot 3154-C as Gil’s property, without the conformity of Artemio and his co-heirs.

In 2005, Gil, joined by his children, filed a Complaint for Quieting of Title and Damages against Artemio, arguing that the 207-square meter property included Lot 3154-A and Lot 3154-C. They claimed Artemio’s construction of a pig pen on Lot 3154-C disturbed their title. Artemio denied these claims, asserting that the sale to the spouses Sillero was limited to Lot 3154-A, and the Subdivision Plan was made without his consent. The Regional Trial Court (RTC) ruled in favor of Gil, declaring him the rightful owner of both Lot 3154-A and Lot 3154-C.

On appeal, the Court of Appeals (CA) reversed the RTC’s decision, concluding that the sale involved only Lot 3154-A and not Lot 3154-C. The CA relied on the testimony of Judith Sillero and the express identification of the lot as Sub-lot 3154-A in the Deed of Sale. The CA also determined that the sale was for a lump sum, not by square meter, and thus Gil could not claim a deficiency. This ruling led Gil to file a Petition for Review on Certiorari with the Supreme Court.

The Supreme Court affirmed the CA’s decision, emphasizing that the key issue was whether the sale between the spouses Sillero and Gil included Lot 3154-C. To resolve this, the Court looked beyond the literal terms of the sale documents and examined the parties’ true intentions. This approach contrasts with a strict application of the Parol Evidence Rule, which generally limits evidence to the written agreement itself.

The Court considered the Absolute Sale and the Deed of Sale as common exhibits, noting that while the Absolute Sale did not specify Lot 3154-A, the Deed of Sale expressly mentioned it. The Court stated,

“[w]hen the parties admit the contents of written documents but put in issue whether these documents adequately and correctly express the true intention of the parties, the deciding body is authorized to look beyond these instruments and into the contemporaneous and subsequent actions of the parties in order to determine such intent.”

Thus, the Court found it necessary to examine parol evidence.

Judith Sillero testified that Artemio presented a sketch plan identifying Lot 3154-A as the portion being sold. Rolando Pis-an, Artemio’s son, confirmed that the spouses Sillero never possessed Lot 3154-C. This evidence supported the conclusion that the sale was specific to Lot 3154-A only. Furthermore, because the spouses Sillero only purchased Lot 3154-A from Artemio, the Court invoked the principle that

“no one can give what one does not have. A seller can only sell what he or she owns x x x, and a buyer can only acquire what the seller can legally transfer.”

Gil’s attempt to claim Lot 3154-C was further undermined by his Affidavit[-]Complaint in the estafa case against the spouses Sillero. In that document, Gil stated that the sold lot was lacking the area of 67 square meters, which would not have been the case if Lot 3154-C was already part of the agreement. The Court found Gil’s testimony unconvincing, noting it was implausible for a former Provincial Agriculturist to buy land without knowing its exact measurements and boundaries. His claim that he simply assumed Lot 3154-C was part of the sale was deemed illogical.

The Supreme Court also dismissed the Subdivision Plan as evidence of Gil’s ownership over Lot 3154-C because it was prepared without the conformity of Artemio and his co-heirs. Moreover, there was doubt as to who initiated the survey, with Gil providing inconsistent answers about the City Engineer’s involvement. As such, the Court concluded the document was secured to create the false impression that the sale between Gil and the spouses Sillero included Lot 3154-C.

Finally, the Court addressed the action for quieting of title, explaining that this remedy is available only to those with legal or equitable title to the property in question. Since Gil failed to demonstrate any legal or equitable title to Lot 3154-C, the action was deemed inappropriate.

FAQs

What was the key issue in this case?	The central issue was whether the sale of land between the spouses Sillero and Gil Macalino included Lot 3154-C, a portion of land across a barangay road from the originally sold property. The court needed to determine if Gil had a legitimate claim to this additional lot based on the circumstances of the sale.
What is the Parol Evidence Rule and why was it not strictly applied here?	The Parol Evidence Rule generally prevents parties from introducing evidence of prior agreements that contradict a written contract. However, the Court bypassed its strict application here because the core issue revolved around the true intent of the parties, which could be better discerned by looking at actions, testimonies, and other documents outside the deed.
What evidence did the Court consider to determine the parties’ true intent?	The Court considered the testimony of Judith Sillero, the testimony of Rolando Pis-an, Gil Macalino’s Affidavit-Complaint in the estafa case, and the actions and conduct of the parties involved in the sales transactions. This included actions taken after the sales, like the fencing of the property and the construction of a house.
Why was the Subdivision Plan not considered strong evidence of Gil’s ownership?	The Subdivision Plan was not considered strong evidence because it lacked the conformity of Artemio and his co-heirs, who were the registered owners of the land. Additionally, there were doubts about who initiated the survey, and it was issued after Gil discovered that the area of Lot 3154-A was less than he expected.
What does "quieting of title" mean in this context?	Quieting of title is a legal action taken to remove any cloud or uncertainty regarding the ownership of real property. In this case, Gil Macalino filed a complaint for quieting of title to establish his ownership over Lot 3154-C.
Why did the Court rule that the remedy of quieting of title was not available to Gil?	The Court ruled that the remedy of quieting of title was not available to Gil because he did not have legal or equitable title to Lot 3154-C. Since he failed to prove that he owned or had a valid interest in the property, he could not use the action to remove any perceived clouds on the title.
What is the significance of the phrase "no one can give what one does not have" in this case?	This legal principle means that a seller can only sell what they legally own. Since the spouses Sillero only bought Lot 3154-A from Artemio and his co-heirs, they could not legally sell Lot 3154-C to Gil, as they never had ownership or rights to that property.
What practical lesson can be learned from this case regarding property sales?	It is crucial for buyers to conduct thorough due diligence before purchasing property, including verifying the exact boundaries, area, and technical descriptions of the land. Additionally, the intent of all parties should be documented as clearly as possible to avoid future disputes.

The Supreme Court’s decision in Macalino v. Pis-An highlights the importance of scrutinizing the intent of parties in property disputes, especially when written documents are ambiguous. It underscores that courts may look beyond the literal wording of deeds to consider actions, testimonies, and other evidence that reveal the true understanding and agreement between the parties. This ruling serves as a reminder that clear documentation and thorough due diligence are essential to avoid future disputes over property ownership.

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: GIL MACALINO, JR. VS. ARTEMIO PIS-AN, G.R. No. 204056, June 01, 2016