Title
Bergado vs. Court of Appeals
Case
G.R. No. 84051
Decision Date
May 19, 1989
A 1928 land sale by Marciana Trinidad led to a double sale in 1947, with the Republic acquiring the property. Petitioners, heirs of the first buyers, claimed ownership but were barred by prescription and laches due to 34-year inaction. The Supreme Court ruled in favor of the Republic, citing bad faith in petitioners' late registration and superior rights of the first possessor.
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Case Digest (G.R. No. 84051)

Facts:

  1. Property in Dispute: The case involves approximately 5,900 square meters of land in Pangasinan, covered by Original Certificate of Title No. 16545 in the names of Alejandro Trinidad and Aniceta Soriano. The land was inherited by their sole heir, Marciana Trinidad.

  2. First Sale (1928): Marciana Trinidad sold the property to Pedro Bergado and Justina Galinato (petitioners' parents) through an Escritura de Compraventa dated May 3, 1928.

  3. Second Sale (1947): Marciana Trinidad sold the same property again on February 19, 1947, to the Parent-Teacher Association (PTA) of the Urdaneta Community High School.

  4. Donation to the Republic (1977): The PTA donated the land to the Republic of the Philippines on July 26, 1977.

  5. Petitioners' Claim: The petitioners, heirs of Pedro Bergado and Justina Galinato, claimed ownership of the property by inheritance. They argued that the Republic was barred from raising defenses of prescription and laches since these were not pleaded earlier.

  6. Possession and Improvements: The PTA and later the Republic took possession of the land, constructed improvements (e.g., buildings, fences), and paid realty taxes. The petitioners did not protest these actions until 1981, when they filed a complaint to nullify the Republic's title.

  7. Registration of Escritura de Compraventa: The petitioners registered the Escritura de Compraventa in 1964, 36 years after its execution, but did not take possession of the land.

Issue:

  1. Prescription and Laches: Whether the petitioners' claim is barred by prescription and laches due to their inaction for over 30 years.

  2. Double Sale: Whether the Republic, as the second buyer, has a superior claim over the petitioners under the rules of double sale.

  3. Good Faith in Registration: Whether the petitioners' registration of the Escritura de Compraventa in 1964 was done in good faith, given their knowledge of the Republic's possession.

  4. Applicability of Torrens System: Whether the petitioners' registered title under the Torrens system makes their claim imprescriptible.


Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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