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...

Facts:

Background of the Parties

• The parties are brothers, both sons of Gregorio Cagaoan.
• Eugenio Cagaoan is the plaintiff and Felix Cagaoan is the defendant and cross-complainant.

Execution of Deeds of Gift

• On November 3, 1915, Gregorio Cagaoan executed a deed of gift of four parcels of land located in the municipality of Tayug, Province of Pangasinan in favor of Felix Cagaoan.
• On October 26, 1918, he executed another deed of gift in favor of Eugenio Cagaoan for a parcel of land.
• This parcel is apparently identical to parcel No. 4 as described in the gift deed in favor of Felix.
• Both deeds were executed using Gregorio’s thumb-print, rendering them authentic and free from formal defects, and both donees accepted the gifts.

Possession and Registration Details

• Eugenio Cagaoan took possession of the donated parcel immediately after execution of the deed in his favor; however, he did not get the donation recorded with the Register of Deeds due to discrepancies between the land description provided in the deed and that in the registry.
• The deed executed in favor of Felix was duly recorded on June 10, 1919.
• Felix appears to have possessed parcels Nos. 1, 2, and 3 since at least 1915, but he never took possession of parcel No. 4.

Death of the Donor

• Gregorio Cagaoan died on December 16, 1918.
• This fact is crucial as it sealed the status of the gifts under his execution.

Legal Action and Proceedings

• Eugenio Cagaoan initiated an action to:
• Declare himself the owner of the disputed parcel;
• Set aside, for fraud, the deed of gift made in favor of Felix Cagaoan; and
• Order the cancellation of Felix’s recorded title in the Register of Deeds.
• Felix Cagaoan filed a cross-complaint seeking:
• Judicial possession of the disputed land; and
• Damages for its “unlawful detention” by the plaintiff.
• The trial court rendered a judgment in favor of Felix, ordering the plaintiff to surrender possession of the disputed parcel and pay the costs.

Allegations and Indications of Fraud

• Evidence indicated that some form of deception was practiced upon Gregorio Cagaoan at the time of executing the deed in favor of Felix.
• The indications suggest that he might not have intended to donate parcel No. 4 to Felix.
• Despite the difficulty of obtaining direct evidence of fraud when the deceived party is unavailable as a witness, the circumstances, left unexplained by Felix, were considered sufficient to raise a fraud claim.

Comparative Analysis with Double Sale Cases

• The court analogized the case to instances where the same property is sold by the same vendor to different vendees.
• Under Article 1473 of the Civil Code and related case law, priority is given based on:
• First registration in the property registry in good faith; or
• First possession in good faith, if the title is unregistered; and, absent both, the oldest title provided good faith can be established.

Notice and Good Faith Considerations

• It was clearly established that Felix had full notice of Eugenio’s claim before his deed was recorded.
• Consequently, Felix was not treated as a third person who could benefit from the legal fiction which ordinarily protects registrants with an unknowledgeable position regarding adverse claims.

Issue:

Question on Priority of Rights

• Whether the plaintiff, having taken possession of the disputed parcel in good faith, has a superior right over the defendant who recorded his deed with the Register of Deeds later on.
• How does the timing of possession versus registration affect title priority in cases of conflicting deeds of gift?

Fraud and Deception in Conveyance

• Whether there is sufficient evidence to uphold the claim that fraud was practiced upon the donor in executing the gift deed in favor of Felix.
• How the alleged fraud impacts the validity and effectivity of the deed subsequently recorded in favor of Felix.

Applicability of the Civil Code and Mortgage Law Principles

• Whether the principles enunciated under Article 1473 of the Civil Code regarding double sales apply analogously to deeds of gift.
• The extent to which the provisions on registration and the doctrine of good faith—as interpreted in prior decisions and in relation to Article 34 of the Mortgage Law—affect the outcome.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)