G.R. No. 108515 October 16, 1995
LUIS BALANTAKBO, AMADEO BALANTAKBO and HEIRS OF SANCHO BALANTAKBO, petitioners, vs. COURT OF APPEALS and LAGUNA AGRO-INDUSTRIAL, COCONUT COOPERATIVE, INC., respondents.

FACTS

Private respondent Laguna Agro-Industrial Coconut Cooperative, Inc. (LAGUNA) filed an action to quiet title over a parcel of unregistered coconut land in Laguna. LAGUNA claimed its predecessors, the Sumaya spouses, purchased the land from Consuelo Vda. de Balantakbo in 1955 for a lump sum of P800.00, as evidenced by a deed describing the property as having an area of 2,000 square meters, “more or less,” with specified boundaries. Petitioners, the heirs of the seller, intruded upon the land in 1975, harvesting coconuts. They contended that only a 2,000-square-meter portion within the described boundaries was sold, and they owned the remaining area, asserting the total land within the boundaries was about 6,870 square meters.
The Regional Trial Court ruled in favor of the Balantakbos, holding that the phrase “more or less” in the deed referred only to a slight difference in area and could not encompass the excess of 4,870 square meters. On appeal, the Court of Appeals reversed the decision, declaring LAGUNA the owner of the entire land within the stated boundaries, ruling that the boundaries control over the stated area.

ISSUE

In case of a conflict between the stated area and the actual boundaries of land in a deed of sale, which should prevail?

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The legal logic is anchored on the well-settled rule that in a sale of land for a lump sum, or a cuerpo cierto, the specific boundaries stated in the contract control over any statement regarding the area contained within those boundaries. The area is considered a mere additional description, often based on estimates, while the boundaries objectively define the limits and identity of the property sold. Consequently, the vendor is obligated to deliver all the land included within the agreed boundaries, regardless of whether the actual area is more or less than the figure stated in the deed.
The Court distinguished the case from Asiain v. Jalandoni, cited by petitioners, where the area was the main consideration of the sale. Here, the sale was for a lump sum, and the land was sufficiently identified by its boundaries. Therefore, LAGUNA, as the buyer’s successor, was entitled to the entire land within the described boundaries, not merely a 2,000-square-meter portion. The error in the stated area was deemed immaterial.