G.R. No. L-11531, L-11532, L-11533; May 30, 1958
Maria Concepcion, petitioner, vs. The Payatas Estate Improvement Co., Inc., respondent.

Alfonso Cruz, petitioner, vs. The Payatas Estate Improvement Co., Inc., respondent.
Angel Sta. Maria, et al., petitioners, vs. The Payatas Estate Improvement Co., Inc., respondent.

FACTS

Three interrelated cases were jointly heard in the Court of First Instance of Rizal, which rendered a single decision in favor of the plaintiffs-petitioners. The defendant-respondent, The Payatas Estate Improvement Co., appealed. The Court of Appeals ordered the remand of the cases to the court of origin for the reception of additional evidence. The plaintiffs-petitioners sought a review of this resolution by certiorari.
The core dispute involves whether certain lots were part of the bed of the San Mateo River at the time of sale by the respondent to the petitioners or their predecessors-in-interest, or whether they were lands within the respondent’s titled property.
1. In G.R. No. L-11531 (Civil Case No. 1476), petitioner Maria Concepcion claims that when she and Gregorio Diaz bought Lot No. 92 in 1925, its southeast boundary was the San Mateo River, and the river later receded, leaving dry the river bed now identified as Lot No. 12. The respondent contends the southeast boundary was land within its titled property.
2. In G.R. No. L-11532 (Civil Case No. 1477), petitioner Alfonso Cruz claims that when his father bought Lots Nos. 95, 96-Q, and 97 (the latter surrounded by the river) in 1926-1927, the eastern boundary was the San Mateo River, and the river later receded, leaving dry the river bed now identified as Lots Nos. 4, 5, 6, 7, and 14. The respondent contends these lots were bounded by land within its titled property.
3. In G.R. No. L-11533 (Civil Case No. 1478), petitioners Angel Sta. Maria, et al., claim that when they bought Lot No. 94-F in 1929, its eastern boundary was the San Mateo River, and the river later receded, leaving dry the river bed now identified as Lots Nos. 8, 9, and 10. The respondent contends the eastern boundary was land within its titled property.
The deeds of sale described the boundaries as stated by the petitioners. The respondent offered parol evidence to prove that, at the time of the sales, the disputed lots were no longer part of the riverbed, the river having changed course earlier. The trial court rejected this evidence, holding it would alter the deeds and that the respondent was in estoppel. The Court of Appeals, without ruling on estoppel, found that the respondent’s answers sufficiently alleged that the deeds did not express the true intent, as the technical descriptions were merely copied from old titles, and thus remanded for additional evidence.

ISSUE

Whether the Court of Appeals correctly ordered the remand of the cases to the trial court for the reception of additional parol evidence to show the actual condition of the disputed lots at the time of the sales, despite the boundary descriptions in the deeds of sale and the petitioners’ claim of estoppel.

RULING

The Supreme Court affirmed the resolution of the Court of Appeals, subject to qualifications. The Court held that the respondent’s answers, while not employing precise legal wording, sufficiently alleged that the deeds did not express the true agreement and that the technical descriptions were copied verbatim from old titles—a common practice in conveyances of registered property. Therefore, the respondent should be allowed to present evidence on the actual condition of the lots at the time of sale.
The Court declined to rule definitively on the plea of estoppel at this stage, noting nothing in the record indicated the petitioners were misled by the alleged inaccuracy to their detriment. Pleadings and remedial laws should be construed liberally to allow litigants ample opportunity to prove their claims and avoid a denial of substantial justice due to technicalities. The issue of whether the respondent is estopped should be settled after the admission of the additional evidence.
The resolution remanding the cases was affirmed, without costs.