Petitioner
Luis Asiain
Respondent
Benjamin Jalandoni
Citation
G.R. No. 20435
Court
Supreme Court
Division
Second Division
Ponente
Malcolm, J.
Decided
October 23, 1923

Summary

Luis Asiain sold land to Benjamin Jalandoni for P55,000, representing it as 25-30 hectares with 2,000 piculs sugar production capacity. The actual area was only 18+ hectares producing 800 piculs. Both courts found mutual mistake regarding essential contract elements. The Supreme Court applied Civil Code Article 1471, distinguishing this from contracts of hazard and finding the deficiency too material to be covered by 'more or less' language. The Court emphasized that mutual mistake going to the contract's essence justifies rescission, putting parties back to their original positions. The decision established important precedent on when area deficiencies in land sales warrant rescission versus price adjustment, balancing contractual certainty with equitable relief for material mistakes.

Statutes applied

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By the Intellegal Editorial Board · October 23, 1923

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