Rafael S.

Ortaez vs Court of Appeals et al

Gr. No. 107372, January 23, 1997
Francisco, J.:
Facts:
Private respondent sold to petitioner two parcels of land for a consideration of 35,000
pesos and 20,000 pesos respectively. The private respondent received the payments but
failed to deliver the titles to petitioner. Petitioner demanded the private respondent to
deliver the titles. The private respondent claims that the first lot is in the possession of
another and the acquisition of title of the petitioner of the other lot is subject to certain
conditions but these conditions are not stated in the Deed of Absolute Sale. Then, the
.petitioner sued private respondent for specific performance before the RTC.
ISSUE:
Whether or not the parol evidence can be admitted to establish the oral conditionsprecedent to a contract of sale are silent on such conditions.
HELD:
No. The failure of the agreement to express the true intent of the parties can be used
to admit parol evidence is applicable where the contract is ambiguous or obscure in term
that the contractual intention of the parties cannot be understood from a mere reading of
the instrument. In such case extrinsic evidence of the subject matter of the contract of the
relations of the parties to each other and the facts and circumstances surrounding them
when they entered into a contract may be received to enable the court to make a proper
interpretation of the instrument.
In this case, the deeds of sale are clear, without any ambiguity, mistake or
imperfection, much less obscurity or doubt in the terms thereof.