Manila Electric Co. v. Heirs of Spouses Deloy

Manila Electric Co. v. Heirs of Spouses Deloy


Respondents are the owners, by way of succession, of a parcel of land consisting of 8,550 square meters located in Trece Martires City (Trece Martires property). Dionisio, respondents’ predecessor-in-interest, donated a 680-square meter portion (subject land) of the 8,550 square meter property to the Communications and Electricity Development Authority (CEDA) for the latter to provide cheap and affordable electric supply to the province of Cavite. A deed of donation was executed to reflect and formalize the transfer. Sometime in 1985, CEDA offered for sale to MERALCO, its electric distribution system, consisting of transformers and accessories, poles and hardware, wires, service drops, and customer meters and all rights and privileges necessary for providing electrical service in Cavite. This was embodied in a memorandum of agreement (MOA), signed by the parties. Thereafter, MERALCO occupied the subject land. MERALCO, through its Assistant Vice President and Head of the Legal Department, Atty. L.D. Torres (Atty. Torres), wrote a letter to Dionisio requesting the latter’s permission for the continued use of the subject land as a substation site. The parties were not able to reach any agreement. Respondents offered to sell the subject land to MERALCO, but their offer was rejected. For said reason, respondents demanded that MERALCO vacate the subject land. Despite the written demand, MERALCO did not move out of the subject land. Thus, respondents were constrained to file the complaint for unlawful detainer.

MTCC rendered the decision dismissing respondents’ complaint for unlawful detainer against MERALCO. The RTC affirmed the MTCC ruling that the latter had no jurisdiction to interpret contracts involving the sale of the subject land to MERALCO. The CA set aside the RTC ruling. 


Whether or not evidence aliunde, such as the letters of Petitioner’s Assistant Vice President and Head of Legal Department Atty. Torres and Internal Memorandum of Petitioner which purportedly recognized Respondent’s ownership of the property can prevail over the deed of absolute sale.


MERALCO posits that extrinsic evidence, such as the letter request, dated October 11, 1985, and the Internal Memorandum, dated December 6, 1985, cannot contradict the terms of the deed of sale between CEDA and MERALCO pursuant to Section 9, Rule 13022 of the Rules of Court.

The Court has combed the records and is not convinced.

It is undisputed that on October 11, 1985 or four (4) months after the approval of the MOA and the corresponding Deed of Absolute Sale, MERALCO, through its Assistant Vice President and Head of the Legal Department, Atty. Torres, sent a letter to Dionisio seeking his permission for the continued use of the subject land. Relative thereto, L.G. de la Paz of the Trece Martires Substation of MERALCO sent the December 16, 1985 Internal Memorandum, addressed to Atty. G.R. Gonzales and Atty. Torres, informing them of some obstacles in reaching a lease agreement with the Deloys. Evidently, by these two documents, MERALCO acknowledged that the owners of the subject land were the Deloys. It is clear as daylight. The first letter was written barely four (4) months after the deed of sale was accomplished. As observed by the CA, MERALCO never disputed the declarations contained in these letters which were even marked as its own exhibits. Pursuant to Section 26, Rule 130 of the Rules of Evidence, these admissions and/or declarations are admissible against MERALCO.

SEC. 26. Admissions of a party — The act, declaration, or omission of a party as to a relevant fact may be given in evidence against him.

In Heirs of Bernardo Ulep v. Ducat, 24 it was written, thus:

. . . Being an admission against interest, the documents are the best evidence which affords the greatest certainty of the facts in dispute. The rationale for the rule is based on the presumption that no man would declare anything against himself unless such declaration was true. Thus, it is fair to presume that the declaration corresponds with the truth, and it is his fault if it does not.

Guided by the foregoing rules and jurisprudence, the Court holds that the letter and the internal memorandum presented, offered and properly admitted as part of the evidence on record by MERALCO itself, constitute an admission against its own interest. Hence, MERALCO should appropriately be bound by the contents of the documents.

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