Case Digest (G.R. No. 92310)
Facts:
The case revolves around a dispute over ownership of a 19-hectare parcel of land in Las Piñas, Rizal, originally sold by spouses Andres Diaz and Josefa Mia to Bruno Gundran on March 29, 1972. The sale was documented with the issuance of Transfer Certificate of Title (TCT) No. 287416, and the owner's duplicate copy of the title was handed over to Gundran. However, Gundran did not register the Deed of Absolute Sale due to advice from the Register of Deeds regarding existing notices of lis pendens on the title. Subsequently, on November 20, 1972, Gundran entered into a Joint Venture Agreement with the Agricultural and Home Extension Development Group (the petitioner), represented by Nicasio D. Sanchez, Sr., for the improvement and subdivision of the land, but this agreement was also not annotated on the title.
On August 30, 1976, the same property was sold again by the Diaz spouses to Librado Cabautan, the private respondent. Following this, on September 3, 1976, a new own...
Case Digest (G.R. No. 92310)
Facts:
1. Initial Sale and Joint Venture Agreement
On March 29, 1972, spouses Andres Diaz and Josefa Mia sold a 19-hectare parcel of land in Las Piñas, Rizal, to Bruno Gundran. The owner’s duplicate copy of the title (TCT No. 287416) was handed over to Gundran, but he did not register the Deed of Absolute Sale due to notices of lis pendens on the title.
On November 20, 1972, Gundran entered into a Joint Venture Agreement with the petitioner, Agricultural and Home Development Group, for the improvement and subdivision of the land. This agreement was also not annotated on the title.
2. Second Sale and Registration
On August 30, 1976, the same spouses sold the land again, this time to Librado Cabautan, the private respondent. On September 3, 1976, a new owner’s copy of the title was issued to the Diaz spouses, who claimed the original was lost. The notices of lis pendens were canceled, and the Deed of Sale in favor of Cabautan was registered. A new title (TCT No. S-33850/T-172) was issued in his name.
3. Legal Proceedings
Gundran filed an action for reconveyance against Cabautan and Josefa Mia on March 14, 1977, seeking the cancellation of TCT No. 33850/T-172 and the issuance of a new title in his name. The petitioner later filed a complaint in intervention with similar claims.
4. Lower Court and Court of Appeals Decisions
The Court of First Instance dismissed Gundran’s complaint and the petitioner’s complaint in intervention in a decision dated January 12, 1987. On appeal, the Court of Appeals affirmed the dismissal but ordered Josefa Mia to pay Gundran P90,000.00 with interest.
Issue:
- Whether Librado Cabautan, the second purchaser, is an innocent purchaser for value entitled to ownership under Article 1544 of the Civil Code.
- Whether Cabautan acted in bad faith despite the notices of lis pendens and the prior sale to Gundran.
- Whether the petitioner’s claim of possession of the property affects Cabautan’s ownership.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)