Title
Balatbat vs. Court of Appeals
Case
G.R. No. 109410
Decision Date
Aug 28, 1996
Aurelio Roque sold his 6/10 property share to Repuyans, later resold it to Balatbat. SC ruled Repuyans' prior registration under Article 1544 gave them superior rights; Balatbat failed to prove good faith.
A

Case Digest (G.R. No. 109410)

Facts:

Clara M. Balatbat filed a petition for review under Rule 45 seeking to set aside the August 12, 1992 decision of the Court of Appeals in CA-G.R. CV No. 29994 affirming the trial court's dismissal of her complaint and recognizing the validity of a prior sale to Jose Repuyan and Aurora Repuyan. The controversy arose from an original partition suit filed on June 15, 1977 in the Court of First Instance of Manila (Civil Case No. 109032), which resulted in a March 29, 1979 decision dividing the conjugal property and led to the issuance on October 5, 1979 of Transfer Certificate of Title No. 135671 showing Aurelio A. Roque owning a six-tenths share. On April 1, 1980 vendor Aurelio Roque executed a Deed of Absolute Sale conveying his 6/10 share to the Repuyans, who caused an affidavit of adverse claim to be annotated on the title on July 21, 1980. Vendor Roque thereafter filed a complaint for rescission on August 20, 1980 (Civil Case No. 134131) for nonpayment of the balance, but the trial court on April 15, 1986 dismissed the rescission action and declared the April 1, 1980 sale valid and enforceable; petitioner had moved to intervene in that action but did not prosecute a complaint in intervention. Meanwhile, pursuant to a partition order of February 2, 1982 under Section 10, Rule 39, a deed of sale was executed on February 4, 1982 conveying the property to petitioner and others, and petitioner obtained a writ of possession on September 20, 1982 subject to valid third-party rights. Petitioner later filed a complaint on December 9, 1988 for delivery of the owner's duplicate copy of TCT No. 135671 against the Repuyans; the Regional Trial Court, Branch 24, dismissed the complaint on August 2, 1990 and awarded the defendants a counterclaim; the Court of Appeals affirmed on August 12, 1992 with modification deleting awards of P10,000 attorneys' fees and P5,000 costs; the present petition to the Supreme Court was dismissed on August 28, 1996.

Issues:

Was the April 1, 1980 sale to Jose Repuyan and Aurora Repuyan merely executory or a consummated and enforceable sale? Did the circumstances constitute a double sale within the meaning of Article 1544 of the New Civil Code? Was Clara M. Balatbat a purchaser in good faith and for value entitled to prevail over the Repuyans? Did the Court of Appeals err in considering evidence allegedly not formally offered by the private respondents?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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