Errors in property documents are more common than many buyers realize, especially in older transactions involving inherited land that has not yet been individually titled. What happens if your deed of sale names the wrong lot?

In a decision involving a 491-square-meter property in Cebu City, the Supreme Court ruled that a land sale remains valid even if the deed contains an incorrect lot number, as long as the parties’ true agreement can be clearly shown. The Court allowed the deed to be reformed and ordered the cancellation of the title later issued to another set of buyers.

The decision, dated December 3, 2025, was written by Associate Justice Henri Jean Paul B. Inting of the Third Division and reported in July 2026.

What happened

The land was part of the estate of Margarita Lopez. Spouses Genara and Felipe Abay Sr. bought the shares of Crispin Caballes and the heirs of Trinidad Caballes-Gallardo through a 1979 Contract to Sell, a 1981 Absolute Deed of Sale, and a 1982 Extrajudicial Settlement and Sale.

Before the purchase, the sellers personally walked the Abays through the property to point out its boundaries. The Abays then:

enclosed the land, first with a bamboo fence;
built a permanent concrete perimeter wall, with the help of one of the sellers’ heirs;
occupied the property and paid real property taxes for about 20 years.

Years later, workers hired by spouses Jacinto and Chiok Ngo Lim Young entered the land, destroyed the wall, and put up new posts. The Abays discovered that a title had been issued in the Youngs’ name, based on a 1999 sale by other heirs of Margarita Lopez.

The Youngs and some of the heirs argued that the Abays’ deeds referred to Lot No. 6036-B, a different and non-adjacent lot, not Lot No. 7, the lot the Abays actually occupied.

The Regional Trial Court ruled for the Abays.
The Court of Appeals reversed, relying on the literal lot number in the deeds.
The Supreme Court reversed the Court of Appeals and reinstated the trial court’s ruling.

The Supreme Court’s ruling

1. The deed can be reformed to reflect what the parties really agreed

Under the Civil Code, a written contract may be reformed when, because of mistake, fraud, inequitable conduct, or accident, it does not express the parties’ true agreement. Citing earlier cases, the Court said reformation is allowed when:

there was a meeting of the minds on the transaction;
the written instrument does not express their true agreement; and
the failure was due to mistake, fraud, inequitable conduct, or accident.

All three were present:

The 1979, 1981, and 1982 documents showed that the sellers agreed to transfer their shares to the Abays for an agreed price.
The parties’ conduct showed they meant Lot No. 7. The sellers walked the buyers through the site, the buyers fenced it, and a seller’s heir even helped build the concrete wall. The Court noted that sellers would not help build permanent structures on land they did not intend to sell.
The reference to Lot No. 6036-B was a clerical mistake. Individual titles had not yet been issued because the estate was still being settled. Lot No. 6036-B also measured 4,450 square meters, while the deeds covered 491 square meters, exactly the combined shares of the sellers in Lot No. 7.

The Court also stressed a practical point: ordinary buyers buy land as they see it on the ground, with its visible boundaries, monuments, and improvements, not by its technical lot number.

2. The later buyers were not buyers in good faith

The Youngs claimed they bought the property in good faith. The Court disagreed. The Abays’ open, long-standing possession, including a concrete wall around the property, should have prompted any prudent buyer to investigate who was occupying the land and on what basis. Because the Youngs failed to inquire, they could not claim good faith, and their later registration did not defeat the Abays’ earlier rights.

Practical lessons for buyers and sellers

Check the technical description carefully before signing a deed of sale, especially for inherited or untitled land, or land that is part of an estate.
Inspect the property, not just the title. If someone else is occupying the land, ask why. Ignoring visible occupants can cost you your claim to good faith.
Take and keep possession. Fencing, building improvements, and paying real property taxes all helped prove the Abays’ case.
Fix errors early. If you discover a mistake in your deed, an action for reformation or a corrective deed is far easier to pursue before a dispute arises.
Settle estates properly. Many disputes like this begin with heirs selling portions of land that has not been fully partitioned and titled.

How Recososa Law Firm can help

Our Real Estate and Property Law and Litigation teams assist clients with due diligence before buying, correcting defective deeds, title cancellation and quieting of title cases, and estate settlement, including properties in Cebu and the rest of the Visayas. Contact us to have your property documents reviewed.

This article is a simplified summary of a reported Supreme Court decision for general information only. It is not legal advice. Read the full text of the decision and consult a lawyer about your specific case.

Wrong Lot Number in Your Deed of Sale? Supreme Court Upholds a Cebu City Land Sale