Case Digest

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LECHUGASV.

CAPRINCIPLE:FACTS:
Victoria Lechugas (petitioner) bought a land from a certain Leoncia Lasangue.
After the purchase of the land, theDeed of Absolute Sale executed by Leoncia
Lasangue in her favor specified a certain land Lot No. 5456 stated in thecontract.
Then the defendants (respondents) occupied Lot No. 5456, petitioner filed a

complaint for forcible entry withdamages against against the defendants butitwas dismissed.
Petitioner appealed the case to the CFI (now RTC) of Iloilo. While theappeal for the ejectment
case was pending, petitioner filed another case in the RTC for the recovery of the
possessiona g a i n s t t h e s a m e d e f e n d a n t s i n v o l v i n g t h e s a m e
L o t N o . 5 4 5 6 . During the trial,the defendants (respondentspresentedtheir witness in
the person of Leoncia Lasangueherself. Leoncia Lasanguetestified during the trial that according
to her, the lot that she sold to the petitioner was not Lot No. 5456 but another
lot,Lot 5522. Lasangue did not know how to read and write, so the document of
sale was prepared by the petitioner,thereafter, the former was made to sign it.
Based on her testimony, the lot indicated in the Deed of Sale which she soldt o
petitioner was erroneous. It was clear that she did not
intend to sell a piece of land already sold by
h e r father to the predecessor1in1interest of the defendants
(respondents). This was objected by the petitioner under theparole evidence
rule.
ISSUE:
WhetherornottheParole EvidenceRuleapplyinthiscase
HELD
: The Court resolved in the negative. The Parole evidence rule will not apply in this
case because it is LeonciaLasangue who is one of the parties to the subject Deed
of Sale not the defendants. The defendants in the case &ere notparties to the
Deed of Sale executed between Leoncia Lasange and petitioner Lechugas. The
rule is not applicablew h e r e t h e c o n t r o v e r s y i s b e t w e e n o n e
of the parties to the document and third persons.
T h e d e e d o f s a l e was executed by Leoncia Lasangue in favor of Victoria
Lechugas. The dispute over that was actually sold is betweenpetitioner and the
private respondents. In the case at bar, through the testimony of Leoncia
Lasangue, it was shown thatthat she really intended to sell and to be the subject
of Exhibit A was Lot No. 5522 but not being able to read and
writea n d f u l l y r e l y i n g o n t h e g o o d f a i t h
o f h e r fi r s t c o u s i n , t h e
petitioner, she just placed her thumb mark on apiece of
paper which petitioner told her was the document evide
n c i n g t h e s a l e o f l a n d . T h e d e e d o f s a l e described the disputed
lot instead

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