G.R. No. L-28064 July 16, 1980
SEBIA ERICO, applicant-appellant, vs. HEIRS OF LUIS CHIGAS and HEIRS OF GUIPOK GUIDSOLAN, oppositors-appellees.

FACTS

Sebia Erico applied for the registration of two parcels of land in Benguet. The Heirs of Luis Chigas and Heirs of Guipok Guidsolan opposed, claiming portions thereof. The trial court granted Erico’s application but ordered her to convey specific areas to the oppositors, as delineated in Exhibit “1-A-Guidsolan” (9,023 sq. m.) and Exhibit “1-B-Chigas” (10,293 sq. m.). The Court of Appeals affirmed this but modified the order, directing the segregation of these delineated portions and the issuance of separate titles for the oppositors at their expense, instead of requiring a deed of conveyance from Erico.
Upon remand, a conflict arose regarding the implementation of this final judgment. Erico submitted a subdivision plan allocating to the Chigas heirs only Lot 1 (10,294 sq. m.), which was less than the total area enclosed within the boundaries of Exhibit “1-B-Chigas.” The oppositors submitted an amendment plan showing that the area within the fixed boundaries of Exhibit “1-B-Chigas” was actually 16,193 sq. m., and that for Exhibit “1-A-Guidsolan” was 9,157 sq. m. The trial court approved the oppositors’ plan in its Order of October 23, 1964, leading Erico to appeal.

ISSUE

Whether the trial court, in its implementing order, erred by awarding areas larger than the specific square meterages mentioned in the final judgment of the Court of Appeals.

RULING

The Supreme Court affirmed the trial court’s order. The legal logic is anchored on the settled principle that in land registration and property law, when there is a conflict between the area measurement and the boundaries described in a judgment, the boundaries control. The final judgment of the Court of Appeals did not merely award abstract areas of 10,293 and 9,023 square meters; it specifically awarded the portions of land “delineated in” the identified exhibits. These exhibits established clear and definite natural boundaries, such as trees, canals, and fences. The trial court’s factual finding that these fixed boundaries encompassed areas of 16,193 sq. m. and 9,157 sq. m., respectively, was a proper implementation of the appellate court’s decree to give the parties what justly appertained to them. The order did not alter the judgment but correctly gave effect to its true intent by adhering to the controlling boundaries. The Court emphasized that what defines a parcel of land is the boundary, not the estimated area.