G.R. No. L-11736-37 - Toribio JovellaNo. et al. vs. Maria G. Dimalanta

The property in dispute is a parcel of land designated as Lot No. 1, Plan PCS-931, Cadastral Case No. 33, located in the City of Dagupan, Province of Pangasinan.
The land is an unsegregated portion of a larger parcel covered by Certificate of Title No. 25515 in the land records of Pangasinan.

The first sale occurred on April 28, 1941, when Rosario Costes Dimalanta sold the property to Maria G. Dimalanta by means of a public document (Exhibit “A”).
A second sale was executed on June 12, 1943, when the same vendor, Rosario Costes Dimalanta, sold the identical parcel to spouses Toribio Jovellanos and Barbara L. Manuel by another public document (Exhibit “C”).

Neither of the deeds of sale was registered under sections 50 and 51 of Act 496 because the parcel sold was not yet fully segregated.
On July 21, 1943, the second purchasers (Jovellanos and Manuel) filed a statement of adverse claim with the Registrar of Deeds, accompanied by a copy of their deed of sale, and filed a petition in the cadastral case under Section 110 of Act 496, seeking registration of their sale (Exhibit “C”) and the issuance of a Certificate of Title.
On August 4, 1943, Maria G. Dimalanta (the first vendee) opposed the petition, praying for the registration of her deed of sale (Exhibit “A”) and issuance of the corresponding Certificate of Title.
Pending the cadastral case, Maria G. Dimalanta also instituted Civil Case No. 122 in the Court of First Instance of Pangasinan, seeking a declaration for her to be recognized as the lawful owner, and requesting an injunction against the second purchasers.

The two cases were tried jointly.
On July 24, 1956, the Court of First Instance rendered its decision, holding that assuming both conveyances were genuine, the second purchasers were declared the lawful owners.

The decision was based on their filing of the adverse claim, which established priority in recording, and their early actual possession of the property.

Maria G. Dimalanta appealed the decision, contending that the ruling violated previous decisions in Quimson vs. Rosete and Sanchez vs. Ramos.
The appellate issue centered on whether the lower court's reliance on recording priority under Art. 1473 of the Civil Code (now Art. 1544 of the Civil Code) was correctly applied.

Whether the principle enunciated in Article 1473 of the Civil Code of 1889 (now Art. 1544 of the Civil Code of the Philippines) – granting priority to the purchaser who first records the sale – applies to this case.
Whether the filing of a statement of adverse claim under Section 110 of Act 496 suffices as the necessary act of recording for establishing the second purchasers’ title.

Whether the adverse claim filed by the second purchasers is valid and effective to bind the property until a competent court declares it invalid.
The legal ramifications arising from the fact that the first sale was never recorded, juxtaposed with the subsequent registration by the second purchasers.

Whether the doctrines from Quimson vs. Rosete and Sanchez vs. Ramos are applicable to resolve the dispute on double sale in the present case.
How the decision interplays with the established rule favoring recorded titles over mere possession for real property transactions.