Case Digest (G.R. No. 17900)
Facts:
The case involves Eugenio Cagaoan as the plaintiff and appellant, and Felix Cagaoan, along with the Register of Deeds of the Province of Pangasinan, as the defendants and appellees. The events leading to this case began with their father, Gregorio Cagaoan, who executed two deeds of gift concerning parcels of land in Tayug, Pangasinan. The first deed, dated November 3, 1915, was in favor of Felix Cagaoan, while the second deed, executed on October 26, 1918, was in favor of Eugenio Cagaoan for a parcel that was described as parcel No. 4 in Felix's deed. Both deeds were free from formal defects and were accepted by the donees.
Eugenio took possession of his parcel immediately after the execution of his deed; however, due to discrepancies between the land description in the deed and the registry, he was unable to have his donation recorded. Conversely, Felix's deed was recorded on June 10, 1919, and he had possession of parcels 1, 2, and 3 since 1915, but he never poss...
Case Digest (G.R. No. 17900)
Facts:
Family Background and Donations
- The plaintiff, Eugenio Cagaoan, and the defendant, Felix Cagaoan, are brothers and sons of Gregorio Cagaoan.
- On November 3, 1915, Gregorio Cagaoan executed a deed of gift for four parcels of land in Tayug, Pangasinan, in favor of Felix Cagaoan.
- On October 26, 1918, Gregorio executed another deed of gift for a parcel of land (Parcel No. 4) in favor of Eugenio Cagaoan.
- Both deeds were formally valid and accepted by the donees.
Possession and Registration Issues
- Eugenio took possession of the parcel donated to him immediately after the execution of the deed but failed to register it due to discrepancies in the land description.
- Felix registered his deed on June 10, 1919, and had possession of Parcels 1, 2, and 3 since 1915 but never possessed Parcel No. 4.
- Gregorio Cagaoan died on December 16, 1918.
Legal Action
- Eugenio filed a lawsuit to declare himself the owner of the donated parcel, alleging fraud in Felix's donation and seeking the cancellation of its registration.
- Felix filed a cross-complaint, demanding possession of the land and damages for its unlawful detention by Eugenio.
- The trial court ruled in favor of Felix, ordering Eugenio to surrender possession and pay costs. Eugenio appealed.
Issue:
- Whether there was fraud in the execution of the deed of gift in favor of Felix Cagaoan.
- Whether Eugenio Cagaoan, as the first possessor in good faith, has a superior right to the disputed land over Felix, who registered his deed first but had prior notice of Eugenio's claim.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court ruled in favor of Eugenio Cagaoan, recognizing his superior right to the disputed land based on his prior possession in good faith and Felix's prior notice of his claim. The registration of Felix's deed was deemed ineffective due to his lack of good faith.