**Case Digest: Paulino Garcia v. Maria Bisaya, et al. (G.R. No.

L-8060, September 28, 1955)**

**Facts:**

Paulino Garcia filed a complaint against Maria Bisaya and others in the Court of First Instance of Oriental Mindoro. Garcia
alleged that on November 12, 1938, the defendants executed a deed of sale in his favor for a parcel of land. However, the
deed mistakenly described the land as unregistered when it was actually part of a registered land under Original
Certificate of Title No. 6579. Despite Garcia's requests, the defendants refused to correct the error, leading Garcia to file
a complaint seeking the correction of the deed of sale.

**Issue:**

The main issue in the case was whether Garcia's action to correct the mistake in the deed of sale was still viable,
considering the defense of prescription raised by the defendants.

**Ruling:**

The court affirmed the dismissal of Garcia's complaint but not on the grounds of prescription. Instead, it held that
Garcia's complaint failed to state a cause of action for reformation of the instrument. The court emphasized that an
action for reformation requires an allegation that the instrument to be reformed does not express the real agreement or
intention of the parties. Garcia's complaint did not include such an allegation, nor did it specify what the real agreement
or intention was.

The court also noted that reformation is not meant to create a new agreement but to establish and perpetuate the true
existing one. Furthermore, reformation is only justified if it enables a party to assert rights under the reformed
instrument. In this case, correcting the deed of sale to reflect the land as registered under a Torrens title would not grant
Garcia any rights, as the title was in the name of another person, Torcuata Sandoval.

The court suggested that if Garcia's grievance was due to fraud or misrepresentation, the proper remedy would be the
annulment of the contract, not reformation. However, Garcia's complaint did not seek annulment or contain the
necessary allegations for such an action.

**Connection to Lesson (Requisites for Reformation of Instruments):**

This case illustrates the importance of meeting the requisites for reformation of instruments in a contract. The essential
elements include alleging that the instrument does not express the real agreement or intention of the parties and
specifying what that real agreement or intention is. Reformation is not a means to create a new agreement but to align
the instrument with the actual agreement made by the parties. Additionally, the remedy sought must enable the party to
assert rights under the reformed instrument. If the grievance involves fraud or misrepresentation, the appropriate
remedy may be annulment rather than reformation.
**Case Digest: Yolanda Rosello-Bentir, Samuel Pormida, and Charito Pormida v. Hon. Mateo M. Leanda, RTC, Tacloban
City, Branch 8, and Leyte Gulf Traders, Inc. (G.R. No. 128991, April 12, 2000)**

**Facts:**

- Respondent Leyte Gulf Traders, Inc. (LGT) filed a complaint for reformation of instrument, specific performance,
annulment of conditional sale, and damages against petitioners Yolanda Rosello-Bentir and the spouses Samuel and
Charito Pormida.

- LGT alleged that it entered into a lease contract with Bentir for a parcel of land for 20 years starting May 5, 1968, which
was later extended for four years until May 31, 1992.

- On May 5, 1989, Bentir sold the leased premises to the Pormida spouses without giving LGT a right of first refusal as per
their agreement.

- LGT sought reformation of the contract, claiming that its lawyer inadvertently omitted to include the right of first refusal
in the lease contract.

- Petitioners argued that the alleged mistake was not a ground for reformation and that LGT's claim was barred by laches
for not filing within the prescribed ten-year period.

**Issue:**

Whether the complaint for reformation of instrument filed by LGT has prescribed, and if not, whether LGT is entitled to
the remedy of reformation.

**Ruling:**

- Reformation of an instrument is a remedy in equity to align a written instrument with the real intention of the parties
when an error or mistake has occurred.

- The prescriptive period for actions based on a written contract and for reformation of an instrument is ten years under
Article 1144 of the Civil Code.

- LGT filed its action for reformation 24 years after the execution of the lease contract, exceeding the prescriptive period
and rendering its cause of action time-barred.

- The Court rejected LGT's argument that the prescriptive period should be counted from the alleged extended lease, as
it was not expressly agreed upon and did not fall under the legal provision for an implied new lease (tacita
reconduccion).

- Even if the action was not time-barred, LGT's claim for reformation would not prosper since it was brought after an
alleged breach of contract, which is not the purpose of an action for declaratory relief.

- The Court granted the petition, reversed the decision of the Court of Appeals, and reinstated the order of the Regional
Trial Court dismissing LGT's action for reformation.

**Connection to Lesson (Requisites for Reformation of Instruments in a Contract):**

This case underscores the importance of filing an action for reformation within the prescribed period, which is essential
under Article 1144 of the Civil Code. The ruling reaffirms that reformation is an equitable remedy with limitations, such
as the requirement to file within the statutory period and the necessity for the action to address issues before any
breach or violation of the contract occurs. Understanding these requisites is crucial when seeking reformation of
instruments in contracts to ensure the legality and enforceability of the remedy sought.
**Case Digest: Asuncion Atilano et al. v. Ladislao Atilano et al. (G.R. No. L-22487, May 21, 1969)**

**Facts:**

- Eulogio Atilano I purchased Lot No. 535 in Zamboanga in 1916, which was later subdivided into lots, including Lot No.
535-E.

- In 1920, Eulogio Atilano I sold Lot No. 535-E to his brother Eulogio Atilano II through a deed of sale that mistakenly
referred to Lot No. 535-A instead.

- Eulogio Atilano II and his heirs, plaintiffs in this case, discovered the mistake in 1959 when they resurveyed the land.

- They filed a case in 1960 seeking to exchange possession of Lot No. 535-E (actual possession) with the defendants'
possession of Lot No. 535-A (referred to in the deed of sale).

- Defendants claimed that the error in the deed was involuntary and that both parties intended to convey Lot No. 535-A.

- The trial court ruled in favor of the plaintiffs, emphasizing that the property was registered under the Land Registration
Act, precluding acquisition through adverse possession.

**Issue:**

Whether the deed of sale's error in referring to Lot No. 535-E as Lot No. 535-A warrants reformation of the instrument.

**Ruling:**

- The Supreme Court reversed the trial court's decision, considering the real intention of the parties over technical errors
in the deed.

- The Court noted that the parties' actual possession and activities on the respective lots aligned with their intentions,
irrespective of the mistaken lot numbers in the deed.

- It emphasized that real estate transactions should reflect the actual property and not merely rely on lot numbers in
certificates of title.

- The Court applied the remedy of reformation under the Civil Code when the true intention of the parties is not
expressed in the instrument due to mistake, fraud, inequitable conduct, or accident (Art. 1359, et seq.).

- Reformation was deemed unnecessary as both parties had possessed their respective lots in accordance with their true
intentions.

- The Court ordered mutual deeds of conveyance between the parties to formalize the exchange of possession of Lot No.
535-E and Lot No. 535-A.

- Costs were imposed on the plaintiffs.

**Connection to Lesson (Requisites for Reformation of Instruments in a Contract):**

This case illustrates the importance of aligning legal documents with the true intentions of the parties involved. The
remedy of reformation, provided under the Civil Code, allows for corrections when instruments fail to express the actual
agreement due to mistakes or other factors. In this case, although a technical error occurred in the deed of sale
regarding lot numbers, the Court prioritized the parties' actual intentions and actions, leading to a practical resolution
through mutual deeds of conveyance. Understanding the requisites for reformation, including demonstrating a meeting
of the minds and actual intentions despite document errors, is crucial in ensuring legal agreements accurately reflect the
parties' agreements.
**Case Digest: Marlene Dauden-Hernaez v. Hon. Walfrido de los Angeles et al. (G.R. No. L-27010, April 30, 1969)**

**Facts:**

- Marlene Dauden-Hernaez, a motion picture actress, filed a complaint against Hollywood Far East Productions, Inc., and
Ramon Valenzuela to recover P14,700.00 for her services in two motion pictures and damages.

- The Court of First Instance of Quezon City dismissed the complaint, citing the absence of a written contract and
violation of Articles 1356 and 1358 of the Civil Code.

- Dauden-Hernaez sought reconsideration and admission of an amended complaint, but both were denied.

- The Court addressed procedural issues regarding the dismissal and subsequent motions for reconsideration.

**Issue:**

Whether the Court of First Instance erred in dismissing the complaint due to the absence of a written contract and
violating Articles 1356 and 1358 of the Civil Code.

**Ruling:**

- The Court found procedural errors in the dismissal of the complaint without allowing amendment and in denying the
motion for reconsideration and admission of the amended complaint.

- It clarified that a motion to dismiss is not a responsive pleading, entitling the plaintiff to amend the complaint as a
matter of right before a responsive pleading is served.

- The Court emphasized that amendments to pleadings should be liberally allowed in the furtherance of justice.

- Regarding the main issue, the Court held that the absence of a written contract did not invalidate the agreement for
personal services under Article 1358 of the Civil Code.

- Article 1356 states that contracts are obligatory in whatever form they are entered into, provided essential requisites
like consent, subject matter, and consideration are present.

- Exceptions to this rule are contracts specifically required by law to be in writing or to be proved by writing, none of
which applied to Dauden-Hernaez's contract for services.

- The Court criticized the misunderstanding of the role of written form in contracts, emphasizing that contracts are
generally valid regardless of form, unless explicitly required by law.

- The Court set aside the dismissal order and remanded the case for further proceedings consistent with its decision.

**Connection to Lesson (Requisites for Reformation of Instruments in a Contract):**

This case underscores the importance of understanding the requisites for reformation of instruments in contracts. While
the case primarily addresses the necessity of written contracts under specific legal requirements, it aligns with the
lesson's principles. Reformation of instruments becomes relevant when there are errors, misunderstandings, or defects
in contracts. In this case, the Court clarified that the absence of a written contract did not invalidate the agreement,
highlighting the importance of focusing on essential contract elements like consent and consideration. Understanding
when reformation is necessary, such as in cases of mutual mistake or fraud affecting the agreement's validity, helps
ensure contracts accurately reflect the parties' intentions and obligations.