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Marquez v. Espejo - Case Digest

The Court held that the CA erred in applying the Best Evidence Rule to resolve a land dispute involving conflicting descriptions of property in various documents. The Best Evidence Rule only applies when the contents of a document are disputed, but here there was no dispute over document contents. Rather, there was an intrinsic ambiguity because the documents did not adequately express the true intention of the parties regarding which land was subject to sale, mortgage, and transfer. To resolve this ambiguity, the court should have considered extrinsic evidence rather than limiting itself to the face of the documents alone.

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May Angelica Teneza
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924 views1 page

Marquez v. Espejo - Case Digest

The Court held that the CA erred in applying the Best Evidence Rule to resolve a land dispute involving conflicting descriptions of property in various documents. The Best Evidence Rule only applies when the contents of a document are disputed, but here there was no dispute over document contents. Rather, there was an intrinsic ambiguity because the documents did not adequately express the true intention of the parties regarding which land was subject to sale, mortgage, and transfer. To resolve this ambiguity, the court should have considered extrinsic evidence rather than limiting itself to the face of the documents alone.

Uploaded by

May Angelica Teneza
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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23.  G.R. No.

 168387, August 25, 2010 The CA rejected any other evidence that could shed light on
SALUN-AT MARQUEZ and NESTOR DELA CRUZ the actual intention of the contracting parties. It appears that CA
Petitioners, v. ELOISA ESPEJO, ELENITA ESPEJO, actually applied was the Parol Evidence Rule instead when it
EMERITA ESPEJO, OPHIRRO ESPEJO, OTHNIEL refused to look beyond the words of the contracts.
ESPEJO, ORLANDO ESPEJO, OSMUNDO ESPEJO,
ODELEJO ESPEJO and NEMI FERNANDEZ, Respondents. However, even the application of the Parol Evidence Rule is
improper in the case at bar. In the first place, respondents are
Facts: The Espejos mortgaged their 2 parcels of land - Lantap not parties to the VLTs executed between RBBI and
Property (LP) and Murong Property (MP) to Rural Bank of petitioners; they are strangers to the written contracts. Parol
Bayombong, Inc (RBBI). Upon failure to pay, the properties evidence rule is exclusive only as between the parties and their
were foreclosed and sold to RBBI. Transfer certificate titles are successors-in-interest.
as follows: TCT No. T-62096 for Murong Property; TCT No. T-
62836 for the Lantap Property. But, the instant case falls under the exceptions to the Parol
Evidence Rule.
After a month, the Espejos bought back the LP from RBBI.
However, the Deed of Sale mentioned TCT No. 62096 as the Here, it was squarely put in issue that the written agreements
subject property which refers to the MP. failed to express the true intent of the parties.

Meanwhile, pursuant to RA 6657, RBBI executed separate The resolution of the instant case necessitates an examination
Deed of Voluntary Land Transfer (VLTs) and CLOAs in favor of of the parties respective parol evidence, in order to determine
petitioners Marquez and dela Cruz. The VLTs mentioned an the true intent of the parties. Well-settled is the rule that in case
agricultural land located in Brgy. Murong as the subject of doubt, it is the intention of the contracting parties that
property but the TCT No. mentioned therein refers to the LP. prevails, for the intention is the soul of a contract,[45] not its
wording which is prone to mistakes, inadequacies, or
After more than 10 years, the Espejos filed a complaint before ambiguities.
the RARAD for the cancellation of petitioners’ CLOAs.
Petitioners insisted that they bought the MP as farmer-
beneficiaries and that the property that was repurchased by the
Espejos was actually the LP as evidenced by the continued
occupation of Nemi Fernandez therein. RBBI, also, answered
that it was, indeed, the LP which was subject of the buy-back
transaction with the respondents.

The OIC-RARAD gave precedence to the TCT numbers which


appeared on the Deed of Sale, VLTs and CLOAs.
On appeal, DARAB reversed the decision of the OIC-RARAD.
However, the CA did not agree with the DARAD’s decision. It
ruled that, using the Best Evidence Rule, the Deed of Sale is
the best evidence as to its contents, particularly the description
of the land which was the object of the sale.

Issue: Whether or not the CA erred in applying the Best


Evidence Rule in the case.

Held. Yes. The CA erred in its application of the Best Evidence


Rule. The Best Evidence Rule states that when the subject of
inquiry is the contents of a document, the best evidence is the
original document itself and no other evidence is admissible as
a general rule.
In the instant case, there is no room for the application of the
Best Evidence Rule because there is no dispute regarding the
contents of the documents.
The real issue is whether the admitted contents of these
documents adequately and correctly express the true intention
of the parties.
This dispute reflects an intrinsic ambiguity in the contracts,
arising from an apparent failure of the instruments to
adequately express the true intention of the parties. To resolve
the ambiguity, resort must be had to evidence outside of the
instruments.

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