Rita Sarming v. Cresencio Dy

Summary

This case involves a dispute over the reformation of a deed of sale between heirs of the Flores family. In 1956, the grandchildren of Jose Flores sold their half-share of Lot 4163 to Alejandra Delfino, but due to a mistake in document preparation, the deed incorrectly described the property as Lot 5734. Alejandra took possession of the correct lot (4163) and occupied it for decades. When the error was discovered, Silveria Flores (the co-owner) refused to correct the deed. The Supreme Court applied Article 1359 of the Civil Code, finding that all requisites for reformation were present: there was a meeting of minds between parties, the instrument failed to express their true intention, and this failure was due to mistake in lot designation. The Court affirmed the reformation of the deed to reflect the true intention of selling Lot 4163, emphasizing that reformation is proper when a written instrument fails to express the parties' true agreement due to mistake, fraud, inequitable conduct, or accident.