Rule 130

Parol Evidence
Robles vs Lizarraga Hermanos
GR No. L-26173 1927
FACTS: As administratrix of the estate of her husband Zacarias Robles, Sr., Anastacia de la
Rama she leased the hacienda “Nahalinan” to Zacarias Robles, Jr. for six years.
Robles, Jr., at his expense and without any right of indemnity at the end of the term, made
various improvements and additions to the plant, such as new hydraulic press, reconstruction of
dwelling house, building of camarins, reconstruction of ovens, and others. Anastacia died, and
three years before the lease was to expire, Lizarraga Hermanos, a mercantile partnership,
proposed to buy all of the property belonging to the hacienda.
As Robles, Jr., still had over two years in his lease contract, he was asked to surrender such last
two years and permit Lizarraga Hermanos to take possession as buyer. Lizarraga Hermanos
agreed to pay him the value of all betterments made on the hacienda and to buy from him all that
belonged to him personally on the hacienda.
However, no reference of such surrender of Robles’ rights as lessee, except in fixing the date
when the lease should end, nor of anything said concerning the improvements or property of a
personal nature, was placed in the instrument of conveyance later executed. Robles, Jr.,
eventually filed a complaint against Lizarraga Hermanos for the recovery of compensation for
improvements made by him on the hacienda and the value of implements and farming equipment
supplied by him, as well as damages for breach of contract.
As evidence, he presented a letter written by Severiano Lizarraga to him, in which a reference is
made to an appraisal and liquidation. Lizarraga Hermanos, however, assailed the admission of
the letter as being prohibited parol evidence.
ISSUE: WON the subject letter is admissible as evidence apart from the instrument of
conveyance
HELD: YES. The rule against the admission of parol evidence does not extend so far as to
preclude the admission of extrinsic evidence to show prior or contemporaneous collateral parol
agreements between the parties, but such evidence may be received, regardless of whether or not
the written agreement contains any reference to such collateral agreement, and whether the
action is at law or in equity
The purpose of parol evidence is to enforce an independent or collateral agreement constituting
an inducement ot the making of the sale, or part of the consideration therefor. There is no rule of
evidence of wider application than that which declares intrinsic evidence inadmissible either to
contradict or vary the terms of a written contract, such being deemed to supersede 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. In this case, the
deed of conveyance purports to transfer to Lizarraga Hermanos only such interests in certain
properties as had come to the conveyors by inheritance, not those which Robles, Jr. had acquired
by lease or purchase, or those that he had placed thereon by way of improvement. The verbal
contract established in this case is therefore clearly independent of the main contract of
conveyance, and evidence of such is admissible under the doctrine above stated. The written
contract is complete in itself, the oral agreement is also complete in itself, and it is a collateral to
the written contract, notwithstanding the fact that it deals with related matters