Vergara Zuñiga Law Office

Vergara Zuñiga Law Office We provide notarial services. ⚖

25/07/2026

The (SC) has ruled that a sale of land remains valid even if the deed of sale designates a different lot number from what was actually sold, as long as the parties’ true agreement can be clearly shown. The deed may then be corrected to match what the parties actually agreed to.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division upheld the sale of a 491-square-meter parcel of land in Cebu City between buyers Genara and Felipe Abay, Sr. (the Abays) and sellers Crispin Caballes and the heirs of Trinidad Caballes-Gallardo (the Gallardos), despite the mistake in the designation of the lot number in the deed of sale.

The property formed part of the estate of Margarita Lopez, who had nine children, including Crispin and Trinidad.

The Abays visited the site with Crispin and Tomas Gallardo, one of Trinidad’s heirs before buying the property. During the visit, they were showed them the land’s boundaries. Tomas even helped the Abays build a concrete fence around it.

The Abays openly occupied the property for about 20 years until their possession was disrupted when workers of spouses Jacinto and Chiok Ngo Lim Young (the Youngs), who are claiming ownership over the property, entered it, destroyed the fence, and built their own posts.

The Abays discovered that a title over the property had been issued in the Youngs’ name. This prompted them to file a complaint before the Regional Trial Court (RTC) to cancel the title.

The Gallardos challenged this, arguing that the documents the Abays presented referred to a different lot, Lot No. 6036-B, and not the lot they were occupying, which was Lot No. 7. While both lots were located in the same area, they were separate properties and were not beside each other. The Youngs supported the Gallardos’ position and maintained that they were buyers in good faith.

The RTC ruled in favor of the Abays which ruling was reversed by the Court of Appeals (CA). The CA held that the documents presented by the Abays showed that they purchased Lot No. 6036-B and not Lot No. 7, which they claimed to own and possess.

The SC disagreed and reiterated its pronouncements in previous cases upholding the validity of the sale and allowing the correction of a contract to reflect the parties’ true agreement in instances where the deed of sale failed to accurately describe the land intended by the parties.

The SC stressed that a person buys property based on what they see on the ground, such as its boundaries, landmarks, and improvements, and not by its technical lot number. Ordinary buyers cannot be expected to identify property based only on survey descriptions or legal documents.

Under the 𝘊𝘪𝘷𝘪𝘭 𝘊𝘰𝘥𝘦, a written document may be corrected when, because of a mistake, it does not express the parties’ actual agreement.

The SC explained that a contract may be reformed or corrected if: (1) the parties agreed on the transaction; (2) the written document does not express their true agreement; and (3) the error was caused by a mistake, fraud, accident, or unfair conduct.

In this case, all these requirements were present.

Thus, the Court declared deemed reformed the Deeds of Sale and Extrajudicial Settlement and Sale by changing the designation of the property sold from “Lot No. 6036-B” to “Lot 7” and the Abays as absolute owners of such property.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=169523

Read the full text of the Decision at https://sc.judiciary.gov.ph/266298-spouses-genera-and-felipe-abay-sr-et-al-vs-spouses-jacinto-s-young-et-al/

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution

24/05/2026

Kung pigang-piga na ang mga binubuwisan tulad ng ating mga middle class na nagkakandakuba na sa pagtatrabaho pero kulang na kulang pa rin ang pantustos sa mga bayarin, tungkulin ng gobyerno na pagaanin ang kanilang pasanin.

Under our proposed measure, the House counterpart version which fully adopts Senate Bill No. 267 filed by Sen. Bam Aquino, we seek to ease the burden on low- and lower-middle-income earners by increasing the income tax exemption ceiling for individual taxpayers from P250,000 to P480,000 annually.

Sa nagtataasang presyo ng krudo, kuryente, tubig, pagkain at iba pang bilihin, panahon na para taasan ang take-home pay ng marami nating mga kababayan, lalo na ang mas nangangailangan. ✊🏼

Hello! We are looking for a co-tenant to share our spacious office and to maximize its use. The office is currently too ...
23/05/2026

Hello! We are looking for a co-tenant to share our spacious office and to maximize its use. The office is currently too spacious for our law office alone, making it an excellent opportunity for another business to occupy part of the space. ✨

Ideal for:
• Retail store
• Professional office
• Start-up business
• Virtual office setup

For interested parties, feel free to message us for more details or to schedule a viewing. We are located at National Highway, Narra, Palawan, near DPWH.


Space for Rent
Rental Space
Commercial Space

For self-employed individuals, pwd pa kayo humabol before May 15 😌
12/05/2026

For self-employed individuals, pwd pa kayo humabol before May 15 😌

14/04/2026

Pinalawig natin ang deadline ng filing ng 2025 Annual Income Tax Returns mula April 15 hanggang May 15, 2026. Mas may oras ang bawat taxpayer na makapag-file nang maayos, kasama ang lahat ng kailangang dokumento, at walang ipapataw na penalties.

Maaaring mag-file at magbayad sa pamamagitan ng BIR electronic platforms, o sa mga Authorized Agent Banks.

Ginawa natin ito para mas magaan ang pagbabayad ng bawat Pilipino, lalo na sa panahong ramdam ang pagtaas ng presyo ng langis. Tuloy-tuloy ang ating ginagawa para maibsan ang bigat sa araw-araw na buhay ng ating mga kababayan.

12/04/2026

Hindi mo magagamit yung 3% withholding of percentage tax sa ITR mo kasi naka 8% ka.

In case may government client/customer ka, tapos 8% yung tax type mo, i-inform mo agad yung government agency, para hindi kana kaltasan ng 3% percentage tax.

Sayang din yun.

PS: Reminder to file and pay Annual ITR on or before April 15. Kung may 2307 ka na claim sa ITR, mag submit din ng SAWT.

Kapag hindi mo alam paano to gawin, tapos wala ka pang budget pang hire ng bookkeeper or accountant, and ayaw mo magkaroon ng penalties.

Meron akong recorded training ng 3-Day Annual ITR na pwede mong pagaralan.

Yung details kung paano ka makaka-access, nasa FEATURED post dito sa loob ng group 👉 EC TAXPH Business Community

Comment 'ITR' para ma-approve ko agad yung request mo.

May oras pa.
Abot kapa.
Simulan mo na ngayon.

11/04/2026

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