Short answer. Yes, by an action for reformation of the instrument. Where the parties did reach a meeting of minds but the document fails to express their true intention through mistake, fraud, inequitable conduct or accident, either party may ask the court to correct the writing so that it says what was agreed.
What the law says
When, there having been a meeting of the minds of the parties to a contract, their true intention is not expressed in the instrument purporting to embody the agreement, by reason of mistake, fraud, inequitable conduct or accident, one of the parties may ask for the reformation of the instrument to the end that such true intention may be expressed.
Civil Code, Article 1359 — Reformation of Instruments. Read the full provision →
What the law says
If mistake, fraud, inequitable conduct, or accident has prevented a meeting of the minds of the parties, the proper remedy is not reformation of the instrument but annulment of the contract.
Civil Code, Article 1359 — Reformation of Instruments. Read the full provision →
Reformation corrects the paper, not the bargain
Article 1359 of the Civil Code allows a party to ask that a document be rewritten to match what was actually agreed: where their true intention is not expressed in the instrument purporting to embody the agreement, by reason of mistake, fraud, inequitable conduct or accident, one of the parties may ask for reformation to the end that such true intention may be expressed. The contract itself is not in question — it stands. What is challenged is the accuracy of the writing that records it: a wrong lot number, an omitted term both sides discussed, an interest rate typed differently from the one agreed.
The dividing line: was there a meeting of minds at all?
This is the distinction the article exists to draw, and it decides which case you have. Its second paragraph is explicit: If mistake, fraud, inequitable conduct, or accident has prevented a meeting of the minds of the parties, the proper remedy is not reformation of the instrument but annulment of the contract. So if the parties genuinely agreed and the scrivener got it wrong, the remedy is to fix the document. If they never agreed in the first place because one of them was mistaken or misled about what he was assenting to, there is nothing to correct — the remedy is to undo the contract altogether.
Conduct can close the door
Article 1367 provides that a party who has brought an action to enforce the instrument cannot afterwards ask for its reformation. You cannot sue on the document as written, see how that goes, and then ask to have it changed. That makes the sequence of steps important from the beginning. It is also why a party who spots a discrepancy should raise it in writing promptly rather than continuing to perform under the flawed text while deciding what to do.
What settles these cases
Reformation is won on the record of the negotiation rather than on the parties' recollections. Earlier drafts, the offer and acceptance, the letter of intent, the computation sheets, the survey plan, the messages settling a figure — anything contemporaneous that shows the agreed term differs from the one that ended up in the deed. Bring those together before deciding what to file, because the same set of documents will also show whether the true problem is a mis-recorded agreement or the absence of any agreement at all.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Spouses Feliciana and Angel Cesa vs. Spouses Elisa Montano Brucelas and David Brucelas, G.R. No. 255564, March 5, 2025 — read the decision on LawPhil →
- Proceso Quiros, et al. vs. Marcelo Arjona, et al, G.R. No. 158901, March 9, 2004 — read the decision on LawPhil →
- Florencia T. Huibonhoa vs. Court of Appeals, et al, G.R. No. 95897, December 14, 1999 — read the decision on LawPhil →
- La Filipina Uy Gongco Corporation vs. Harbour Centre Port Terminal, Inc, G.R. No. 229490, March 1,2023 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 1359 — Reformation of Instruments
- Civil Code, Article 1361 — Reformation for Mutual Mistake
- Civil Code, Article 1367 — Enforcement Bars Reformation
- Civil Code, Article 1390 — Voidable Contracts