Case Digest (G.R. No. 138201)
Facts:
The case involves a dispute over ownership of a parcel of land located in Prieto-Diaz, Sorsogon, originally inherited by the legitimate children of the deceased spouses Juan Canino and Brigida Domasig. The heirs included Preciosa Canino, Consolacion Canino, Dolores Canino, Isidra Canino, and Tomas Canino. On December 15, 1947, Preciosa Canino executed an unnotarized "Deed of Sale of Real Property with Right of Repurchase" in favor of Julia Deocareza, which was followed by several other transactions involving the same property. Notably, on April 29, 1968, Julia Deocareza sold the property to Gaudioso Nogales, the respondent, through a "Deed of Absolute Sale," which was duly registered.
In the years that followed, various portions of the property were sold to the petitioners—Francisco Bayoca, Nonito Dichoso, and spouses Pio and Dolores Dichoso, as well as Erwin Bayoca—who claimed ownership based on their respective deeds of sale. The petitioners argued tha...
Case Digest (G.R. No. 138201)
Facts:
- Property Ownership and Succession: The subject property originally belonged to the spouses Juan Canino and Brigida Domasig, who died intestate. Their children inherited the property, with each having a pro indiviso share. Tomas Canino, one of the heirs, was a minor and under the care of his sister, Preciosa Canino.
- Sale with Right to Repurchase: Preciosa Canino executed several unnotarized "Deed of Sale of Real Property with Right of Repurchase" in favor of her sister-in-law, Julia Deocareza, covering portions of the property. These deeds were executed between 1947 and 1951. Preciosa failed to repurchase the property within the stipulated periods.
- Subsequent Sale to Respondent: On April 29, 1968, Julia Deocareza sold the property to respondent Gaudioso Nogales through an unnotarized "Compromise Agreement" and a "Deed of Absolute Sale." The deed was registered on May 3, 1968. Nogales acquired the property and later demanded possession from the occupants.
- Trial Court Ruling: Nogales filed a complaint for recovery of possession against the occupants, including the Deocareza family. The trial court ruled in favor of Nogales, ordering the defendants to vacate the property and pay damages. This decision was affirmed by the Court of Appeals.
- Petitioners' Claims: Petitioners Francisco Bayoca, Nonito Dichoso, spouses Pio and Dolores Dichoso, and Erwin Bayoca claimed ownership over portions of the property. They relied on subsequent sales executed by Preciosa Canino and her siblings, as well as certificates of title issued in their names. They argued that their titles should prevail over Nogales' claim.
Issue:
- Priority of Ownership: Whether the petitioners’ claim of ownership, based on their respective titles and registrations, prevails over that of the respondent.
- Jurisdiction: Whether the Regional Trial Court had jurisdiction over the case, considering the petitioners’ claim that the land is public agricultural land.
Ruling:
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court ruled that respondent Gaudioso Nogales, as the first buyer, had a superior right to the property. The petitioners' claims, based on subsequent sales and titles, were invalid because they were purchasers in bad faith and failed to register their claims in good faith.
Ratio:
Article 1544 of the Civil Code: In cases of double sales of immovable property, ownership is transferred in the following order:
- The first registrant in good faith.
- The first in possession in good faith.
- The buyer who presents the oldest title in good faith.
Nogales, as the first buyer, registered the sale in good faith, which gave him priority over the petitioners.
Good Faith in Registration: The petitioners failed to register their sales in good faith. They were aware of Nogales' prior claim, as evidenced by the ongoing litigation and the registration of the property under Act No. 3344. Their titles, though issued, were tainted with bad faith and could not prevail over Nogales' prior registration.
Jurisdiction: The Court rejected the petitioners’ argument that the property was public agricultural land. The prior grant of free patents and the registration of the property under Act No. 3344 removed it from the public domain, giving the trial court jurisdiction over the case.
Estoppel: The petitioners were estopped from claiming the property as public land, as they had actively participated in the proceedings and relied on their certificates of title as their principal defense.
Conclusion:
The Supreme Court upheld the principle of "first in time, first in right" under Article 1544 of the Civil Code. Since Nogales was the first to register the sale in good faith, his claim to the property was superior to the petitioners'. The petitioners' titles, though issued, were invalid due to bad faith, and their claims of ownership were dismissed.