Supreme Court: Clerical errors in deeds of sale can be corrected


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The Supreme Court (SC) has ruled that errors in a deed of sale may be corrected to reflect the true agreement of the parties.
In a decision dated 3 December 2025, and released on 24 July 2026, the SC Third Division upheld the validity of the sale of a 491-square-meter parcel of land in Cebu between the buyers, the sellers, and the sellers' heirs.
The Court said an error in the property's designation should not defeat the parties' true intent. It noted that the Civil Code recognizes that when a written instrument fails to express the real agreement because of a mistake, the proper remedy is to interpret and, if necessary, reform the contract to reflect the contracting parties' true intent.
The Court said the buyers had occupied the property for 20 years before their possession was disrupted when a couple entered the land, destroyed their fence, and built their own structure.
The buyers later discovered that the title to the property had been issued in the couple's name, prompting them to file a complaint before the Regional Trial Court (RTC) seeking the cancellation of the title.
The sellers' heirs opposed the complaint, arguing that the buyers presented a document referring to a different property—Lot No. 6036-B—instead of the lot they had occupied, Lot No. 7.
The heirs also claimed that the extrajudicial settlement and deed of sale executed by the sellers had been forged.
The RTC ruled in favor of the buyers, but the Court of Appeals reversed the decision. The SC, however, reinstated the RTC's ruling.
The Court said that under the Civil Code, a written instrument may be corrected if it fails to express the parties' actual agreement because of a mistake.
It added that a contract may be reformed if the parties agreed on the transaction, the written document does not reflect their true agreement, and the error resulted from a mistake, fraud, accident, or inequitable conduct.
The SC ruled that the reference to Lot No. 6036-B in the deeds of sale was merely a clerical error and did not reflect the parties' true agreement.
"The true intention of the parties is readily determinable from the records. The parties' actions before, during, and after the execution of the 1979, 1981, and 1982 deeds of sale demonstrate that the object of the sale is the subject property, not Lot No. 6036-B," the Court said.
The decision was penned by Associate Justice Henri Jean Paul Inting.
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