When Verbal Agreements Speak Loud
Supreme Court Says “Pwede!” on Unwritten Land Sale
In a country where papeles often spell the difference between winning and losing a property case, the Supreme Court recently reminded us that actions—especially in real estate—can speak louder than documents. In a landmark decision, the SC ruled that a land sale sealed only by a verbal agreement can still be considered valid and binding, as long as certain conditions are met.
A Family Land Deal Without a Contract
Sometime before 1974, Mr. Bean sold a piece of land to his nephew, Dickey. Nothing was put in writing. No notarized documents, no deed of sale—just a verbal agreement. But here’s the thing: Dickey wasn’t just all talk. He received the land title, moved into the property, and even made improvements on it. For all practical purposes, he became the new owner.
When Mr. Bean passed away in 1974, his children—Bert and Ernie—were unaware that the land even existed. It wasn’t until 2007 that they found out about it after receiving a notice about unpaid real estate taxes. That’s when they discovered that Dickey had been living on the land for years.
The Legal Battle Begins
Shocked and feeling blindsided, Bert and Ernie filed a case against their cousin, Dickey, claiming they were the rightful heirs of the property since it was still under their father’s name.
Dickey defended himself by saying he bought the land directly from Mr. Bean before his death. Not only that, but he also continued paying for the land in installments to Mario, Mr. Bean’s brother and Bert’s legal guardian. To support his claim, Dickey showed the land title and pointed out that he had made improvements and paid the taxes on the land for years.
At First, the Lower Courts Ruled Against Dickey
Both the Regional Trial Court and the Court of Appeals sided with Bert and Ernie. According to them, the land was still legally under Mr. Bean’s name and without a formal written agreement, Dickey’s story wasn’t strong enough.
Supreme Court Says Otherwise
Enter the Supreme Court. In a ruling penned by Associate Justice Samuel H. Gaerlan, the high court reversed the lower courts’ decisions.
Under the Civil Code of the Philippines, yes, land sales generally need to be in writing to be enforceable. However, the SC clarified that even an oral contract can be legally binding if it’s already been partially or fully executed.
Dickey had taken possession of the land, improved it, received the land title, and paid real property taxes. These acts, the SC said, were enough to prove that a valid sale had taken place—despite the absence of a written contract.
One Catch: Payments to Mario Don’t Count
The payments Dickey made to Mario, Mr. Bean’s brother, weren’t considered valid since Mario wasn’t authorized to receive money on behalf of Mr. Bean’s heirs. So, while the sale remains valid, the SC ruled that Dickey must still pay the remaining balance of the purchase price plus interest to Bert and Ernie.
The Bottom Line: Actions Can Seal a Deal
In real estate, we’re always taught to “put it in writing.” But this decision shows that the courts can—and will—recognize deals sealed with trust and backed up by action.
Conclusion
So mga ka-real estate, kung may kasunduan kayo tungkol sa lupa na hindi naisulat, huwag mawalan ng pag-asa. Basta’t may malinaw na ebidensya na naipatupad na ang kasunduan—tulad ng pagtira, pagbayad ng buwis, at pagpapagawa sa lupa—may laban pa rin. Syempre, mas safe pa rin kung may dokumento, pero this case shows na hindi lahat ng usapang walang papel ay basta-basta pwedeng baliwalain.
In the end, it’s not just about what’s written—sometimes, it’s also about what’s done.
Source (Supreme Court of the Philippines)
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