G.R. No. 211917 - Gamaro vs. People

The dispute involves a double sale of the same parcel of unregistered land.
In Civil Case No. 21 before the Court of First Instance of Leyte, the decision favored defendant-appellee Perfecto Pilapil.
The case was originally appealed by plaintiff-appellant Iluminado Hanopol and then certified to the higher Court for resolution of issues exclusively of law.

Appellant Hanopol claimed title based on a series of purchases executed in 1938 through private instruments by former owners (Teodora, Lucia, Generosa, Sinforosa, and Isabelo) all surnamed Siapo.
Hanopol further relied on a decision rendered in Civil Case No. 412 on his complaint filed on June 16, 1948, against the vendors.

In that complaint, he alleged that the vendors had fraudulently, by threat and intimidation, taken possession of the property in December 1945, ejecting his tenants.
The 1948 decision declared him the exclusive owner of the property and ordered the delivery of its possession by the vendors.

In contrast, appellee Pilapil asserted his title on the basis of a duly notarized deed of sale executed in his favor by the same vendors on December 3, 1945.

This deed was subsequently registered in the Registry of Deeds of Leyte on August 20, 1948, under Act No. 3344.

Hanopol’s evidence consisted exclusively of the private instruments of purchase and a certified copy of the 1948 decision in the revindicatory case against the vendors.
Pilapil relied solely on the notarized deed of sale annotated with its registration under Act No. 3344.
No testimonial evidence was presented; both parties depended entirely on their documentary records.

The trial court’s decision largely rested on the second paragraph of Article 1544 of the New Civil Code (formerly Article 1478 of the old Civil Code), which provides that for immovable property, ownership vests in the person who, acting in good faith, first records the title in the Registry of Property.
The issue involved matters of double sale and the ensuing legal effects of registration under Act No. 3344, particularly the concept of a “better right” and the binding force of judgments on successors in interest.

Whether the judgment in Civil Case No. 412, rendered against the vendors (Siapos), is binding upon appellee Pilapil by virtue of his alleged succession in interest, considering he derived his title from the notarized deed of sale executed on December 3, 1945.
Whether the registration of Pilapil’s notarized deed of sale under Act No. 3344 vests in him a right as the second vendee that is unaffected by the prior claim of the first vendee (Hanopol) who purports to have acquired a better right based solely on earlier private instruments and the earlier judicial decision.