SC: Errors in deed of sale may be corrected to reflect parties' true agreement

The Supreme Court (SC) has ruled that errors in a deed of sale may be corrected to reflect the parties' true agreement. In its decision, the SC Third Division upheld the validity of the sale of a 491-square-meter parcel of land in Cebu between the buyers and the sellers, as well as the sellers' heirs. “Accordingly, the error in designation should not defeat the true intent of the parties. The Civil Code recognizes that when a written instrument fails to express the real agreement due to a mistake, the proper recourse is to interpret and, if necessary, reform the contract in accordance with the true intent of the contracting parties,” it said. The SC said that the buyers occupied the property for 20 years and their possession was disrupted when a couple entered the property, destroyed their fence, and built their own post. The buyers discovered that the title over the property had been issued in the couple’s name, prompting them to file a complaint before a regional trial court (RTC) to cancel the title. The sellers' heirs challenged this, arguing that the buyers presented a document referring to a different property—Lot No. 6036-B—rather than the lot they were occupying, Lot No. 7. The heirs also claimed that the extrajudicial settlement and sale executed by the sellers were forged. The RTC ruled in favor of the buyers, but this was overturned by the Court of Appeals. The SC reinstated the ruling of the RTC. The high court said that under the Civil Code, a written document may be corrected if it does not express the parties’ actual agreement due to a mistake. According to the Court, a contract may be reformed or corrected if the parties agreed on the transaction, the written document does not express their true agreement, and the error was caused by a mistake, fraud, accident, or unfair conduct. The SC ruled that the reference to Lot No. 6036-B in the deeds of sale was merely a clerical error and did not reflect the parties' true agreement. “The true intention of the parties is readily determinable from the records. The parties' actions before, during, and after the execution of the 1979, 1981, and 1982 deeds of sale demonstrate that the object of the sale is the subject property, not Lot No. 6036-B,” it said. The decision, written by Associate Justice Henri Jean Paul Inting, was promulgated in December 2025 and made public in July 2026. —VBL, GMA News