FACTS:

The case involves a dispute over the ownership and title to a real property located in Albay, Philippines. Petitioner Arcaina is the owner of the property and her attorney-in-fact, petitioner Banta, entered into a contract with respondent Ingram for the sale of the property. The contract price was P1,860,000.00, with Ingram making installment payments totaling P1,715,000.00. Ingram discovered that the property had an area of 12,000 sq. m., while the tax declaration covering it stated an area of only 6,200 sq. m. Banta allegedly insisted that the difference of 5,800 sq. m. remains unsold, while Ingram claimed that she owns the whole property by virtue of the sale. Ingram, represented by respondent Archinue, filed a recovery case against petitioners before the MCTC, seeking a declaration of ownership over the entire property and damages. The MCTC dismissed the case for insufficiency of evidence, holding that Ingram failed to prove she paid for the excess area of the property. Petitioners filed a counterclaim for the payment of the remaining balance of the contract.

Noemi Ingram filed a complaint against Dasmariñas Arcaina and Magnani Banta for recovery of ownership and possession of a parcel of land identified as Lot No. 3230. Ingram claimed that she purchased the entire property from Arcaina, but the latter refused to turn over the excess land covered by the boundary indicated in the deeds of sale. The Municipal Circuit Trial Court (MCTC) ruled in favor of Arcaina, stating that Ingram failed to show that she paid for the value of the excess land area. On appeal, the Regional Trial Court (RTC) reversed the MCTC's decision and declared Ingram as the owner of the whole property. The RTC held that neither party presented competent evidence to prove the actual area of the property, and therefore, the area indicated in the deeds of sale should be followed. The Court of Appeals (CA) affirmed the RTC's ruling, but deleted the award of attorney's fees and costs of suit. Petitioners (Arcaina and Banta) moved for reconsideration, arguing that Ingram's claim is already time-barred under Article 1543 of the Civil Code.

ISSUES:

1. Whether the sale of the property was made for a lump sum or on a per-square-meter basis.

2. Whether the action to recover the excess portion of the land is barred by prescription.

3. Whether the vendor is required to deliver all that is included within the boundaries of the immovable, regardless of the actual area stated in the contract of sale.

4. Whether the excess area of 5,800 sq. m. should be delivered to the buyer.

5. Whether the Deed of Absolute Sale clearly and unequivocally indicated that the area sold was only up to 6,200 square meters.

6. Whether the inconsistent and impossible testimonies of the respondent and the spouses Ingram affect the validity and enforceability of the Deed of Absolute Sale.

7. Whether the petitioners have already performed their obligation under the contract of sale.

RULING:

1. The sale of the property was made for a lump sum. The Deed of Sale executed by the sellers indicated a predetermined price of P1,860,000.00 with no indication that the sale was on a per-square-meter basis. Thus, the sale is governed by Article 1542 of the Civil Code, which provides that in a sale of real estate made for a lump sum, there shall be no increase or decrease in the price even if there is a greater or lesser area than that stated in the contract.

2. The action to recover the excess portion of the land is not barred by prescription. Article 1543 of the Civil Code, which provides for a six-month prescriptive period from the delivery of the property, does not apply because the buyer did not intend to rescind the sale. The buyer filed the action to recover the excess portion of the land that the sellers claimed to be unsold, thus the portion remained undelivered.

3. The vendor is generally obligated to deliver all the land covered within the boundaries, regardless of the actual area stated in the contract of sale. However, this obligation only applies when the excess or deficiency between the actual area and the estimated area stated in the contract is reasonable.

4. In this case, the difference of 5,800 sq. m. is too substantial to be considered a reasonable excess. Therefore, the buyer is only entitled to the 6,200 sq. m. of the property that was originally agreed upon by the parties.

5. The Deed of Absolute Sale clearly and unequivocally indicated that the area sold was only up to 6,200 square meters. The agreement of the parties as stated in the document is clear and unambiguous, which renders the inconsistent and impossible testimonies of the respondent and the spouses Ingram irrelevant. The court is convinced that the deed expresses the true intent of the parties.

6. The inconsistent and impossible testimonies of the respondent and the spouses Ingram do not affect the validity and enforceability of the Deed of Absolute Sale. The document itself is sufficient to determine the parties' intent, and no extrinsic aids or further extraneous sources are necessary.

7. The petitioners have already performed their obligation under the contract of sale by delivering the 6,200 square meter property. Since the respondent has yet to fulfill her part of the bargain, she must pay the petitioners the remaining balance of the contract price amounting to P145,000.00.

PRINCIPLES:

• Judicial admissions made by the parties in the pleadings or in the course of the trial or other proceedings in the same case are conclusive and do not require further evidence to prove them. They cannot be contradicted unless previously shown to have been made through palpable mistake or that no such admission was made.

• In sales involving real estate, the parties may choose between a unit price contract or a lump sum contract. In a lump sum contract, where the purchase price is determined by a stated full purchase price and the area and boundaries of the immovable are declared, there shall be no increase or decrease in the price even if there is a greater or lesser area than that stated in the contract.

• When the boundaries of the immovable are declared in a sale of real estate for a lump sum, the area covered within the boundaries prevails over the stated area.

• The vendor is obliged to deliver all that is included within the boundaries of the immovable, regardless of whether the actual area is more than what was specified in the contract of sale.

• The use of "more or less" or similar words in designating quantity covers only a reasonable excess or deficiency.

• A vendee of land sold in a lump sum does not take all the risk of quantity in the land.

• The specific boundaries stated in the contract control over any other statement with respect to the area contained within its boundaries.

• A discrepancy in the area that is too substantial cannot be considered a reasonable excess or deficiency.

• The contract of sale is considered the law between the parties and must be complied with in good faith.

• The intent of the parties to a contract is determined by the document itself, and extrinsic aids or further extraneous sources are not necessary if the agreement is clear and unambiguous.