Robles v. Lizarraga Hermanos Case Digest

Robles v. Lizarraga Hermanos

GR No. L-26173

July 13, 1927

Facts:

Hacienda Nahalinan was originally owned by Zacarias Robles, Sr. and Anastacia de la Rama, the plaintiff’s parents. When Robles Sr. died, de la Rama became the administatrix and leased the hacienda to her son, Zacarias Robles. The lease was to run from May 1915 to May 1920. It was stipulated that any permanent improvements necessary for the cultivation and exploitation to the hacienda should be made at the expense of the lessee without right to indemnity at the end of the term.

Three years before the lease was to expire, de la Rama dies, leaving as heirs Zacarias, Jose, Evarista, Magdalena, and Felix. Jose and Evarista acquired by purchase the shares of their coheirs in the entire inheritance.

Lizarraga Hermanos, a mercantile partnership, proposed to buy all other properties belonging to the Robles estate. It was also proposed that Zacarias would surrender the lst two years of his lease and permit Lizarraga to take possession as purchases in June 1918. In consideration of shortening the lease term, Lizarraga agreed to pay Zacarias the value of all betterments that he had made on the hacienda and to purchase from him all that belonged to him personally on the hacienda.

No reference in the conveyance was made as to the surrender of Zacarias’ rights as lessee except in fixing the date when the lease would end. Zacarias pointed out upon reading the instrument that it was declared that the lease will subsist only up to June 30, 1918 instead of May 1920 and at the same time, there was nothing in the instrument about the promise of Lizarraga to compensate him for the improvements and to purchase the existing crops.

When Zacarias pointed this out, Lizarraga’s representative said that it was unnecessary to do so because of the confidence existing between the parties.

Zacarias did not contract any plans for his sugarcane because he relied on the defendant’s promise to buy the crops from him. Lizarraga later on said that they would not be buying the crops, which caused the plaintiff to lose money by virtue of the delay. During the trial, Lizarraga contended that they had not come into an agreement regarding the crops.

Issues:

Can the contract be proved by oral evidence?

Is the sale enforceable?

Ruling:

1. Yes. While it is true that the execution of a contract in writing is deemed to superseded all oral negotiations or stipulations concerning its terms and the subject-matter which preceded the execution of the instrument, in the absence of accident fraud, or mistake of fact, this rule should be taken with proper qualifications.

It is agreed that proof is admissible of any collateral, parol agreement that is not inconsistent with the terms of the written contract, though it may relate to the same subject-matter.

It has accordingly been held that in case of a written contract of elase, the lessee may prove an independent verbal agreement of the part of the landlord to put the leased premises in a safe condition and a vendor of realty may show by parol evidence that crops growing on the land were reserved, though no such reservation was made in the deed of conveyance.

The verbal contract which the plaintiff has established in this case is therefore clearly independent of the main contract of conveyance and evidence of such verbal contract is admissible under the doctrine above stated.

2. Yes. The defendant invoked Article 335 of the Code of Civil Procedure, which states that a contract for the sale of goods, chattels, or things in action at a price not less than P100, shall be unenforceable unless the contract shall be in writing and subscribed by the parties charged or by his agent. But the Court notes that the section contains a qualification, which is thus stated: “unless the buyer accepts and receives part of such goods and chattels.

It was found by the trial court that the personal property such as farming implements, were ued by Lizarraga in the cultivation of the hacienda.