G.R. Nos. L-39972 & L-40300 August 6, 1986
VICTORIA LECHUGAS, petitioner, vs. HON. COURT OF APPEALS, MARINA LOZA, et al., respondents.

FACTS

Petitioner Victoria Lechugas filed a complaint for forcible entry and a separate action for recovery of possession against private respondents over portions of land. She anchored her claim on a Deed of Absolute Sale (Exhibit “A”) executed in 1950 by Leoncia Lasangue, which described the sold property as a six-hectare portion of Lot No. 5456 of the Lambunao Cadastre, with a technical plan attached. Lechugas asserted she had since possessed the land, declared it for taxation, and paid taxes. The private respondents, the Loza family, resisted her claims, asserting ownership through a prior 1941 sale of the same land by Leoncia’s father, Emeterio Lasangue, to their father, Hugo Loza.
The trial court dismissed Lechugas’s complaints, declaring the Loza respondents as the lawful owners and possessors. The Court of Appeals affirmed. A pivotal point was the testimony of the vendor, Leoncia Lasangue, who testified that the land she actually sold to Lechugas was Lot No. 5522, located south of the disputed property (Lot No. 5456), and that she never intended to sell the land already sold by her father to the Lozas. This testimony was admitted by the appellate court over Lechugas’s objection based on the parol evidence rule.

ISSUE

Whether the Court of Appeals erred in admitting parol evidence (the vendor’s testimony) to vary, contradict, or explain the terms of the notarized Deed of Absolute Sale, which clearly identified the subject property as part of Lot No. 5456.

RULING

The Supreme Court dismissed the petition, upholding the appellate court’s decision. The parol evidence rule, which generally prohibits the introduction of extrinsic evidence to vary or contradict the terms of a written agreement, admits of exceptions. One such exception is when the instrument does not express the true intent and agreement of the parties. The Court found this exception applicable.
The vendor’s clear and categorical testimony established that the true intention of the parties was to convey Lot No. 5522, not the disputed Lot No. 5456. This testimony was credible and consistent with the respondents’ core defense that Leoncia Lasangue had no capacity to sell Lot No. 5456 in 1950, as it had already been sold by her father in 1941. The admission of this evidence was not to reform the deed without an action for reformation, but to ascertain the true agreement and prevent the enforcement of a contract that did not reflect the parties’ actual intent. The Court also found no improper change of theory on appeal, as the respondents’ defense consistently challenged the validity and scope of the deed. The factual findings of the lower courts, supported by evidence, were conclusive.