FACTS:
The case involves a parcel of land in Cebu City originally owned by Pastor Pacres. Upon Pastor's death, his heirs occupied definite portions of the land. The respondents, Ramirez and Ygoña, acquired shares in the ancestral home and the land through purchases from the Pacres siblings. In 1984, Ygoña filed a petition to survey and segregate her portions, which was opposed by Mario Pacres's claim for legal redemption, but was dismissed. In 1993, the government expropriated a portion of the land, and Ygoña sought to withdraw her corresponding share in the expropriation payment, which the petitioners opposed.
The Pacres siblings executed a Confirmation of Oral Partition/Settlement of Estate, which stated that Mario and Veñaranda would have fronting lots, and the rest would have lots at the rear. Mario filed an ejectment suit against Ramirez, which was dismissed. Mario's heirs brought a complaint for specific performance against Ygoña and Ramirez, but the trial court ruled in favor of the respondents. The Court of Appeals affirmed the dismissal, ruling that there was no valid oral partition agreement and that Ygoña's only obligation was the purchase of the shares.
There was a dispute over the partition and ownership of Lot No. 9, as well as the entitlement to an expropriation payment. The petitioners filed a complaint alleging an oral agreement to partition the property and additional obligations of surveying and titling. The trial court ruled in favor of the respondents, finding no evidence of the oral agreement. The Court of Appeals affirmed the validity of the written deeds of sale but reversed the order to survey the lot. The petitioners raised issues regarding the complaint for specific performance, location of the purchased area, alleged abuse of discretion, and ownership of the expropriation payment.
The issues to be resolved are the existence of the alleged oral agreements and whether the ownership of the front portion of Lot No. 9 and entitlement to the expropriation payment can be resolved in this action.
ISSUES:
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Whether petitioners were able to prove the existence of the alleged oral agreements such as the partition and the additional obligations of surveying and titling.
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Whether the petitioners, who are not parties to the contracts of sale, can sue for the enforcement of the obligations arising from said contracts.
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Whether the issue of ownership regarding the front portion of Lot No. 9 and entitlement to the expropriation payment may be resolved in this action.
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Whether or not petitioners have proven the alleged obligations.
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Whether or not petitioners are entitled to specific performance.
RULING:
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The trial and appellate courts' dismissal of the complaint was affirmed as petitioners failed to prove the existence of an oral partition. The lower courts' factual finding that the existence of an oral partition was not proven was deemed justified. Petitioners' only evidence, a joint affidavit executed in 1993, was not sufficient to prove the alleged oral partition. The previous assertion of co-ownership over the same lot in a legal redemption case also contradicted petitioners' claim of partition. Furthermore, petitioners failed to demonstrate that they took actual possession of their allotted shares according to the alleged partition. Thus, it was ruled that the trial and appellate courts did not err in their findings.
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The alleged additional obligations sought to be enforced against respondent Ygoña were also rejected by the trial and appellate courts. Petitioners failed to sufficiently establish that Ygoña agreed to these undertakings as additional consideration for the sale.
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The petitioners, not being parties to the contracts of sale, cannot sue for the enforcement of the obligations. Although third parties can seek enforcement of a contract under Article 1311, the contracts in this case do not contain any stipulation in favor of the petitioners. Furthermore, the Parol Evidence Rule applies, and the alleged oral stipulation cannot be proven. The Rule does not apply to strangers to a contract, but a person claiming to be a beneficiary of a stipulation pour autrui becomes a party to that contract.
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The issue of ownership and entitlement to the expropriation payment should be resolved in the expropriation court. While the existence of forum-shopping cannot be determined due to lack of evidence, it is correct that the issue of ownership should be litigated in the expropriation court. The expropriation court is empowered to adjudicate the rightful owner of the condemned property and is the proper venue for such issues.
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The Court denied the petition and affirmed the decision of the Court of Appeals. The Court ruled that petitioners have failed to prove the alleged obligations and, therefore, are not entitled to specific performance.
PRINCIPLES:
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The Court's review of cases decided by the Court of Appeals is generally limited to questions of law and does not involve re-examining the probative value of the evidence presented.
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Extrajudicial admissions may be given in evidence against the party making the admission.
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Contracts take effect only between the parties, their assigns, and their heirs. Only a party to the contract can maintain an action to enforce the obligations arising under said contract.
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Stipulations pour autrui refers to stipulations for the benefit of third parties.
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The Parol Evidence Rule states that when the terms of an agreement have been reduced to writing, there can be no evidence of such terms other than the contents of the written agreement.
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The Parol Evidence Rule applies to parties and their successors in interest.
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A person claiming to be a beneficiary of a stipulation pour autrui becomes a party to that contract.
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The court hearing an expropriation case is empowered to entertain conflicting claims of ownership and adjudge the rightful owner.
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In order to be entitled to specific performance, the party seeking it must first prove the existence of a valid and enforceable contract and the fact of performance or tender of performance on their part.
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The burden of proof lies with the party claiming a right under specific performance, and such party must establish its entitlement through clear, precise, and convincing evidence.
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The appellate court's ruling on factual matters is generally conclusive on the Supreme Court, unless there are exceptional circumstances that warrant a re-evaluation of the evidence presented.