Spouses Camilo L. Sabio v. The International Corporate Bank

Summary

The Sabio spouses sued Interbank and later the Ayala Group companies for specific performance of a 1985 Memorandum of Agreement requiring transfer of a 58,000 square meter land parcel with right of way. The petitioners demanded that respondents first clear the property of squatters and fence it before transfer. All three court levels ruled that the MOA, when interpreted according to its plain terms, imposed no such obligations on respondents. The Supreme Court emphasized that courts cannot read additional terms into clear written contracts, and that symbolic delivery through a deed of conveyance is legally sufficient even if squatters occupy the property. The Court rejected the Sabios' attempts to introduce parol evidence to modify the written agreement's terms, noting that lawyer Camilo Sabio participated in drafting the MOA and could have included express provisions for clearing squatters if intended. The decision affirmed that easements should be construed in their ordinary meaning and that the proposed right of way adequately served the dominant estate's needs without unnecessarily burdening the servient estate.