G.R. No. L-11531, L-11532, L-11533; May 30, 1958
MARIA CONCEPCION, ALFONSO CRUZ, and ANGEL STA MARIA, ET AL., petitioners, vs. THE PAYATAS ESTATE IMPROVEMENT CO, INC., respondent.

FACTS

These are three interrelated cases jointly heard in the Court of First Instance of Rizal. The petitioners (plaintiffs below) claim ownership over several lots (Lot No. 12 in L-11531; Lots Nos. 4, 5, 6, 7, and 14 in L-11532; Lots Nos. 8, 9, and 10 in L-11533) which they allege are accretions formed by the gradual recession of the San Mateo River. They contend that when they or their predecessors bought adjacent lands from the respondent company in 1925, 1926, 1927, and 1929, those purchased lots were bounded by the San Mateo River. The subsequent recession of the river allegedly left dry the disputed riverbed lots, which should belong to them as riparian owners. The respondent company denies this, asserting that the disputed lots were part of its titled property at the time of the sales and were not part of the riverbed, and that the deeds of sale inaccurately described the boundaries as the San Mateo River because the technical descriptions were merely copied verbatim from old certificates of title. The trial court ruled in favor of the petitioners, rejecting the respondent’s parol evidence aimed at altering the boundary descriptions in the deeds. On appeal, the Court of Appeals ordered the remand of the cases to the trial court for the reception of additional evidence on the actual condition of the lots at the time of the sales. The petitioners sought a review of this resolution by certiorari.

ISSUE

Whether the Court of Appeals erred in remanding the cases to the trial court to allow the respondent to present parol evidence to prove that the disputed lots were not part of the San Mateo River at the time of the sales, despite the boundary descriptions in the deeds of sale.

RULING

The Supreme Court affirmed the resolution of the Court of Appeals. The Court held that the respondent’s answers, while not employing precise legal wording, sufficiently alleged that the deeds of sale did not express the true intent and agreement of the parties and that the disputed lots were not accretions but part of its original property. The practice of copying technical descriptions verbatim from old titles in deeds of conveyance is common. The issue of whether the parol evidence is admissible to show inaccuracy in the deeds, and whether the respondent is estopped from doing so, should be determined after the evidence is presented. 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 petitioners’ arguments on estoppel were not sufficient at that stage to justify overturning the appellate court’s order for remand. The resolution was affirmed without costs.