Carmen del Prado v. Spouses Antonio L. Caballero

Summary

This case involved a dispute over the extent of a land sale between Carmen del Prado and the Caballero spouses. Del Prado purchased Cadastral Lot No. 11909 for P40,000 based on a deed specifying 4,000 square meters 'more or less,' but when the title was issued, it showed 14,457 square meters. Del Prado claimed entitlement to the entire lot under the lump sum sale rule (Article 1542, Civil Code), while the Caballeros insisted they only sold 4,000 square meters. The Supreme Court ruled against del Prado, finding that the 10,475 square meter discrepancy was too substantial to be covered by 'more or less' language, and that evidence showed the parties intended to sell only 4,000 square meters. The Court also found that del Prado used an improper legal remedy and that the title had become incontrovertible. The decision clarifies that 'more or less' in land sales covers only reasonable discrepancies, not substantial differences that would fundamentally alter the transaction's nature.