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...

Facts:

Background of the Property and Inheritance

• A parcel of land in Prieto-Diaz, Sorsogon originally belonged to Spouses Juan Canino and Brigida Domasig, who died intestate before 1947.
• Their legitimate children, including Preciosa Canino, Consolacion Canino, Dolores Canino, Isidra Canino, and Tomas Canino (then a minor), inherited the property pro indiviso.
• The land was initially covered by Tax Declaration No. 9659 with an assessed value of P500.00 and was bounded by several adjacent properties.

Early Sales and Deeds Involving the Inheritors

• On December 15, 1947, Preciosa Canino executed an unnotarized Deed of Sale of Real Property with Right of Repurchase in favor of Julia Deocareza for a 5,000-square-meter portion, reserving the right to repurchase within five years.
• Subsequently, on February 2, 1948, Tomas Canino (then 17) and Preciosa Canino executed a similar unnotarized deed covering 5,330 square meters with a one-year repurchase period.
• On August 29, 1948, Preciosa Canino executed another such deed conveying the entire property to Julia Deocareza with a two-year repurchase period, binding one of the siblings by thumb impression.
• Later, on January 31, 1951, Preciosa Canino executed a notarized Deed of Sale with Right to Repurchase over the entire property in favor of Julia Deocareza for P800.00, covenanting that the property was unencumbered and to be registered under Act 3344.

The Transaction to Gaudioso Nogales and Subsequent Possession

• Julia Deocareza, having acquired the property from the siblings though a series of unnotarized and notarized deeds, sold the property to Gaudioso Nogales.
• On April 29, 1968, she executed a Compromise Agreement and a subsequent Deed of Absolute Sale in favor of Gaudioso Nogales, which was duly registered on May 3, 1968.
• The deed required Julia to have her brothers, Ambrosio and Emilio Deocareza, and their families vacate the premises.
• Gaudioso Nogales, after purchasing the property, had it registered under Act No. 3344.
• Amidst ensuing disputes, litigation was initiated leading to a Regional Trial Court decision in Civil Case No. 975 (February 7, 1983) that ordered defendants, including some of the Canino parties, to deliver possession of the property to Nogales.
• Execution of a Writ by the trial court led to the physical vacating of the property by the occupants, and subsequent acknowledgment of possession by Nogales’ agent.

Subsequent Sales to the Petitioners

• Years after Nogales’ purchase, multiple sales were executed by the Canino siblings:
• On June 21, 1971, Isidra Canino sold Parcel aDa (approximately 5,929 square meters) to Pio Dichoso and Lourdes Donor, which led to the issuance of Free Patent No. V-3-0770 and Original Certificate of Title No. P-11918.
• Later transactions include:
• A sale by Preciosa Canino on June 20, 1979, whereby she sold part of Lot 669 (6,550 square meters) to Erwin Bayoca, resulting in the issuance of TCT No. 27220.

ii. A sale by Consolacion Canino on January 18, 1983, transferring Lot 671 (5,929 square meters) to Nonito Dichoso. iii. A sale by Dolores Canino on August 3, 1987, transferring Lot 667 (7,090 square meters) to Francisco Bayoca. iv. A later sale by Preciosa Canino on October 13, 1989, transferring a parcel (previously covered by OCT No. P-25402) to Erwin Bayoca.

The Emergence of Litigation and Contested Titles

• On September 8, 1992, Gaudioso Nogales filed a complaint for Accion Reinvindicatoria with damages against the petitioners to recover possession of the entire property.
• The trial court, in its Decision dated March 12, 1996, declared Nogales the absolute owner of the disputed property based on the Compromise Agreement and the Deed of Absolute Sale executed in his favor.
• The decree further ordered:
• Eviction of petitioners from the property.
• Removal of structures built by Francisco Bayoca and Nonito Dichoso.
• Reconveyance of titles—specifically enforcing the cancellation of certificates issued to petitioners.
• Payment of damages, attorney’s fees, reimbursement for produce, and costs.
• The Court of Appeals affirmed the trial court ruling without modification and upheld the finding that petitioners were purchasers in bad faith.

Arguments Raised by the Petitioners

• Petitioners contended that their subsequent registrations (and, in some cases, declarations for taxation) gave them superior rights, arguing they were, in effect, the first registrants in their respective portions.
• They also questioned the jurisdiction of the Regional Trial Court by claiming the land was public agricultural land.
• Their position leaned on provisions of Article 1544 of the Civil Code regarding double sales and the protection afforded to buyers registering in good faith.
• The petitioners maintained that the sale to Gaudioso Nogales was subsequently tainted by the later registrations by themselves.

Judicial Findings on the Disputed Transactions

• The evidence clearly showed that Nogales purchased the property earlier from Julia Deocareza and registered the sale properly.
• The registration under Act No. 3344 served as constructive notice, thereby nullifying the good faith claim of the petitioners who registered later or merely declared the property.
• The lower courts held that the petitioners’ transactions occurred long after Nogales’ sale and that their registrations did not achieve the good faith requisite mandated by law.

Issue:

Whether the petitioners’ claim of ownership based on their respective registrations and certificates of title prevails over that of respondent Gaudioso Nogales, who was the first buyer.

• Determination of the effect of registration under Act No. 3344 regarding constructive notice.
• Assessment of what constitutes good faith registration in cases involving multiple sales of immovable property.

Whether the Regional Trial Court had jurisdiction to hear the case, particularly with respect to the claim that part of the land was public agricultural land.

• Consideration of the impact of early registration and free patents that segregated the property from the public domain.
• Examination of the estoppel raised by the petitioners themselves with respect to their prior participatory defense in the proceedings.

Ruling:

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Ratio:

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Doctrine:

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