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Heirs of Pacres v.

Heirs of Ygona ISSUE/S


GR# 110129 | 277 SCRA 215| August 12, 1997 1. W/N the Heirs of Pacres was able to prove the existence of the alleged oral
Petitioner: HEIRS OF MARIO PACRES agreements such the partition and additional obligations of surveying and titling?
Respondent: HEIRS OF CECILIA YGONA

FACTS RULING & RATIO


- The petitioners admit that at the time of Pastors death in 1962, his heirs were - NO
already occupying definite portions of Lot No. 9. The front portion along the o Under Article 1311 of the Civil Code, contracts take effect only
provincial highway was occupied by the co-owned Pacres ancestral home, between the parties, their assigns heirs. Thus, only a party to the
and beside it stood Rodrigo's hut (also fronting the provincial highway). contract can maintain an action to enforce the obligations arising
- Mario's house stood at the back of the ancestral house. The ground floor of under said contract.
the ancestral home together with a lot area of 300 square meters including the o Petitioners, not being parties to the contracts of sale between Ygoña
area occupied by the house to respondent Ramirez, who immediately took and the petitioners’ siblings, cannot sue for the enforcement of the
possession thereof. Subsequently, four of the Pacres siblings sold their shares supposed obligations arising from said contracts. An exception to this
in the ancestral home and the lot on which it stood to Ramirez. is when there is a stipulation for the benefit of third parties or
- The deeds of sale described the subjects thereof as part and portion of the stipulation pour autrui, but none is present here.
300 sqm. actually in possession and enjoyment by vendee and her spouse, o While petitioners claim that there was an oral stipulation, it cannot be
Hilario Ramirez, by virtue of a contract of lease in their favor. proven under the Parol Evidence Rule. “When the terms of an
- With the sale, Ramirez's possession as lessee turned into a co- ownership agreement have been reduced to writing, it is considered as
with Mario and Venaranda (petitioners), who did not sell their shares in the containing all the terms agreed upon and there can be, between the
house and lot. parties and their successors in interest, no evidence of such terms
- Rodrigo, Francisco, and Simplicia sold their remaining shares in Lot No. 9 to other than the contents of the written agreement.” While the Rule
respondent Cecilia Ygona. Margarita also sold her share to Ygona. admits of an exception, no such exception was pleaded, much less
- The complaint for legal redemption, filed by Mario and Venaranda, was proved, by petitioners.
dismissed on the ground of improper exercise of the right. The decision was o The Parol Evidence Rule applies to “the parties and their successors
affirmed by the appellate court and attained finality in the Supreme Court. in interest.” Conversely, it has no application to a stranger to a
- Later, the DPWH, expropriated the front portion of Lot No. 9 for the expansion contract.
of the Cebu south road. o For purposes of the Parol Evidence Rule, a person who claims to be
- The Pacres siblings (represented by their heirs) executed a Confirmation of the beneficiary of an alleged stipulation pour autrui in a contract (such
Oral Partition/ Settlement of Estate of Pastor Pacres. as petitioners) may be considered a party to that contract.
- The court dismissed Mario's assertion that his siblings sold the rear lots to o It has been held that a third party who avails himself of a stipulation
Ramirez. It held that the deeds of sale in favor of Ramirez clearly described pour autrui under a contract becomes a party to that contract. This is
the object of the sale as the ancestral house and lot. why under Article 1311, a beneficiary of a stipulation pour autrui is
- Mario, petitioners’ predecessor-in-interest, filed an ejectment suit against required to communicate his acceptance to the obligor before its
Ramirez’ successor-in-interest Vicentuan. Mario claimed sole ownership of revocation.
the lot occupied by Ramirez/Vicentuan by virtue of the oral partition. o Moreover, to preclude the application of Parol Evidence Rule, it must
- Venaranda and the heirs of Mario filed the instant complaint for specific be shown that “at least one of the parties to the suit is not party or a
performance against Ygona and Ramirez. Contrary to Mario's allegations of privy of a party to the written instrument in question and does not
co-ownership over Lot No. 9 in the legal redemption case, Mario's heirs insist base a claim on the instrument or assert a right originating in the
in the action for specific performance that the heirs agreed on a partition prior instrument or the relation established thereby.” A beneficiary of a
to the sale. stipulation pour autrui obviously bases his claim on the contract. He
- The trial court held that petitioners failed to prove partition of the lot in therefore cannot claim to be a stranger to the contract and resist the
accordance with petitioners’ version, the CA sustained the ruling of the lower application of the Parol Evidence Rule.
court. o Thus, even assuming that the alleged oral undertakings invoked by
petitioners may be deemed stipulations pour autrui, still petitioners’
Hence, this petition. claim cannot prosper, because they are barred from proving them by
oral evidence.

DISPOSITION
Petition partially granted.
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