Heirs of PolicronioUreta, Sr. vs. Heirs of LiberatoUreta
G.R. No. 165748. September 14, 2011
The applicability of the parol evidence rule requires that the case be between parties to the written instrument in question and their successors-in-interest.
Facts:
In his lifetime, Alfonso Ureta (Alfonso) begot 14 children, namely, Policronio, Liberato, Narciso, Prudencia, Vicente, Francisco, Inocensio, Roque, Adela, Wenefreda, Merlinda, Benedicto, Jorge, and Andres. The children of Policronio (Heirs of Policronio), are opposed to the rest of Alfonso's children and their descendants (Heirs of Alfonso).
Alfonso and four of his children, namely, Policronio, Liberato, Prudencia, and Francisco, met at the house of Liberato. He executed four (4) Deeds of Sale covering several parcels of land in favor of his four children in order to reduce the inheritance taxes.
No monetary consideration was given, Alfonso continued to own, possess and enjoy the lands and their produce. Years after Alfonso’s and Policronio’s death, the former’s heirs executed a Deed of Extra-Judicial Partition, which included all the lands that were covered by the four (4) deeds of sale that were previously executed by Alfonso for taxation purposes.
Believing that the six parcels of land belonged to their late father, and as such, excluded from the Deed of Extra-Judicial Partition, the Heirs of Policronio filed a Complaint for Declaration of Ownership, Recovery of Possession, Annulment of Documents, Partition, and Damages against the Heirs of Alfonso. The RTC ruled in favor of the Heirs of Alfonso. Likewise, the CA affirmed the finding of the RTC that the Deed of Sale was void. It found the Deed of Sale to be absolutely simulated as the parties did not intend to be legally bound by it.
Issue: Whether or not parol evidence rule may be properly invoked by either party in the litigation against the other, where at least one of the parties to the suit is not a party or a privy of a party to the written instrument in question and does not base a
claim on the instrument or assert a right originating in the instrument or the relation established thereby.
Held:
Section 9 of Rule 130 of the Rules of Court provides:
Section 9.Evidence of written agreements. — When the terms of an agreement have been reduced to writing, it is considered as containing all the terms agreed upon and there can be, between the parties and their successors in interest, no evidence of such terms other than the contents of the written agreement.
However, a party may present evidence to modify, explain or add to the terms of written agreement if he puts in issue in his pleading:
(a)An intrinsic ambiguity, mistake or imperfection in the written agreement;
(b)The failure of the written agreement to express the true intent and agreement of the parties thereto;
(c)The validity of the written agreement; or (d)The existence of other terms agreed to by the parties or their successors in interest after the execution of the written agreement.
The term "agreement" includes wills.
Paragraphs (b) and (c) are applicable in the case at bench.
The failure of the Deed of Sale to express the true intent and agreement of the parties was clearly put in issue in the Answer of the Heirs of Alfonso to the Complaint. It was alleged that the Deed of Sale was only made to lessen the payment
of estate and inheritance taxes and not meant to transfer ownership. The exception in paragraph (b) is allowed to enable the court to ascertain the true intent of the parties, and once the intent is clear, it shall prevail over what the document appears to be on its face. As the true intent of the parties was duly proven in the present case, it now prevails over what appears on the Deed of Sale.
The validity of the Deed of Sale was also put in issue in the Answer, and was precisely one of the issues submitted to the RTC for resolution. The operation of the parol evidence rule requires the existence of a valid written agreement. It is, thus, not applicable in a proceeding where the validity of such agreement is the fact in dispute, such as when a contract may be void for lack of consideration.
Considering that the Deed of Sale has been shown to be void for being absolutely simulated and for lack of consideration, the Heirs of Alfonso are not precluded from presenting evidence to modify, explain or add to the terms of the written agreement.
Indeed, the applicability of the parol evidence rule requires that the case be between parties and their successors-in-interest. In this case, both the Heirs of Alfonso and the Heirs of Policronio are successors-in-interest of the parties to the Deed of Sale as they claim rights under Alfonso and Policronio, respectively. The parol evidence rule excluding evidence aliunde, however, still cannot apply because the present case falls under two exceptions to the rule, as discussed above.
CIRTEK EMPLOYEES LABOR UNION-FEDERATION OF FREE WORKERS vs. CIRTEK ELECTRONICS, INC.
G.R. No. 190515. June 6, 2011
Theparol evidence rule, like other rules on evidence, should not be strictly applied in labor cases.
Facts:
The then Acting Secretary of Labor Manuel G. Imson ruled that the wage increases to be given are P10 per day effective January 1, 2004 and P15 per day effective January 1, 2005. Respondent averred that the Secretary of Labor cannot insist on a ruling beyond the compromise agreement entered into by the parties.
Issue: Whether or not the parol evidence rule should be strictly applied in labor cases.
Held:
In determining arbitral awards then, aside from the MOA, courts considered other factors and documents including, as in this case, the financial documents submitted by respondent as well as its previous bargaining history and financial outlook and improvements as stated in its own website.
The appellate court's ruling that giving credence to the "Pahayag" and the minutes of the meeting which were not verified and notarized would violate the rule on parol evidence is erroneous.
Theparol evidence rule, like other rules on evidence, should not be strictly applied in labor cases. Interphil Laboratories Employees Union-FFW v. Interphil Laboratories, Inc. teaches:
[R]eliance on the parol evidence rule is misplaced. In labor cases pending before the Commission or the Labor
Arbiter, the rules of
evidence prevailing in courts of law or equity are not controlling. Rules of procedure and evidence are not applied in a very rigid and technical sense in labor cases. Hence, the Labor Arbiter is not precluded from
accepting and
evaluatingevidence other
than, and even contrary to , what is stated in the CBA.
MEINRADO ENRIQUE A. BELLO vs. PEOPLE OF THE PHILIPPINES
G.R. No. 199430 March 21, 2012
Based on theparol evidence rule, there can generally be noevidence of the terms other than the contents of the written agreement
Facts:
Sandiganbayan convicted petitioner of violation of R.A. 3019, Sec. 3 (e) for acting in evident bad faith in the purchase of the property sold by Glicerio Plaza as part of the Armed Forces of the Philippines — Retirement Separation and Benefit System (AFP-RSBS) Calamba Land Banking Project, The Sandiganbayan found that the true consideration of the sale made by Plaza to AFP-RSBS was only P227,460 as stated in a unilateral Deed of Absolute Sale, and not the disbursed amount of P1,531,564 as reflected in the bilateral Deed of Sale.
Issue: Whether or not the unilateral Deed of Sale should be the basis to determine the true consideration.
Held:
In any event, the finding that the true consideration was only P227,460 and not P1,531,564 is supported by the evidence on record.
Here, the Sandiganbayan found that the unilateral Deed of Sale was the official document used by the buyer AFP-RSBS and seller Plaza in the registration of the sale; as well as in the payment of the registration fee, transfer tax, capital gains tax, and documentary stamp tax necessary to effect transfer. This finding was not disputed by the petitioner.
At most, petitioner relied on the testimony of Plaza, which referred to a consideration of P1,137,300 to P1,213,120 as purchase price of the
property. However, based on
the parol evidence rule, there can generally be no evidence of the terms other than the contents of the written agreement; and even if this were the case, it still appears that the consideration cannot be the P1,531,564 disbursed according to the Status Transaction Report signed by petitioner.
Neither did the seller or the buyer dispute the validity of the unilateral Deed of Absolute Sale.
The subsequent bilateral Deed of Absolute Sale did not repeal or modify the earlier sale either. As the deed was a valid agreement of conveyance, notwithstanding that only the seller signed the deed, theSandiganbayan did not err when it used the unilateral Deed of Sale as basis to determine the true consideration.
MODESTO LEOVERASvs. CASIMERO VALDEZ G.R. No. 169985. June 15, 2011
To avoid the operation of the parol evidence rule, the Rules of Court allows a party to present evidence modifying, explaining or adding to the terms of the written agreement if he puts in issue in his pleading, as in this case, the failure of the written agreement to express the true intent and agreement of the parties. The failure of the written agreement to express the true intention of the parties is either by reason of mistake, fraud, inequitable conduct or accident, which nevertheless did not prevent a meeting of the minds of the parties.
Facts:
When BenignaLimas died, she willed her share of a parcel of land equally to her sisters Alejandra Llamas and Josefa Llamas. Thus,
Alejandra and Josefa each owned one-half (1/2) of Benigna's share. On June 14, 1969, Alejandra's heirs sold their predecessor's one-half (1/2) share (roughly equivalent to 10,564 square meters) to the respondent, as evidenced by a Deed of Absolute Sale. Also on June 14, 1969, Josefa sold her own one-half (1/2) share (subject property) to the respondent and the petitioner, as evidenced by another Deed of Absolute Sale.
Years later, the respondent filed a complaint against the petitioner, seeking the reconveyance of the 1,004-square meter portion (disputed property), on the ground that the petitioner is entitled only to the 3,020 square meters identified in the parties' Agreement. On the other hand, the petitioner claimed that the respondent voluntarily participated in executing the Affidavit, which corrected the mistake in the previously executed Agreement and confirmed the petitioner's ownership over the disputed property. He claimed that since the Agreement does not reflect the true intention of the parties, the Affidavit was subsequently executed in order to reflect the parties' true intention.
Issue: Whether or not the written agreement failed to express the true intent and agreement of the parties therefore beyond the ambit of parol evidence rule.
Held:
The petitioner's argument calls to fore the application of the parol evidence rule, i.e., when the terms of an agreement are reduced to writing, the written agreement is deemed to contain all the terms agreed upon and no evidence of these terms can be admitted other than what is contained in the written agreement. Whatever is not found in the writing is understood to have been waived and abandoned.
To avoid the operation of the parol evidence rule, the Rules of Court allows a party to present evidence modifying, explaining or adding to the terms of the written agreement if he puts in issue in his pleading, as in this case, the failure of the written agreement to express the true intent and agreement of the parties. The failure of the written agreement to express the true intention of the parties is either by reason of mistake, fraud, inequitable conduct or accident, which nevertheless did not prevent a meeting of the minds of the parties.
At the trial, the petitioner attempted to prove, by parol evidence, the alleged true intention of the parties by presenting the Affidavit, which allegedly corrected the mistake in the previously executed Agreement and confirmed his ownership of the parcels of land covered by his titles. It was the petitioner's staunch assertion that the respondent co-executed this Affidavit supposedly to reflect the parties' true intention. TCcIaA
In the present petition, however, the petitioner made a damaging admission that the Benigna Deed is fabricated, thereby completely bolstering the respondent's cause of action for reconveyance of the disputed property on the ground of fraudulent registration of title. Since the Affidavit merely reflects what is embodied in the Benigna Deed, the petitioner's admission, coupled with the respondent's denial of his purported signature in the Affidavit, placed in serious doubt the reliability of this document, supposedly the bedrock of the petitioner's defense.