Title
Supreme Court
Lu vs. Spouses Manipon
Case
G.R. No. 147072
Decision Date
May 7, 2002
Dispute over 339-sqm lot ownership; SC ruled respondents had better right, petitioner was buyer in bad faith; ordered conveyance upon payment.

Case Digest (G.R. No. 147072)
Expanded Legal Reasoning Model

Facts:

  • Background Transactions and Non-registration
    • On May 9, 1981, Juan Peralta executed a deed of sale by installment in favor of spouses Orlando and Rosita Manipon (respondents), selling 350 square meters out of his 2,078 square-meter lot (covered by TCT No. 137911, located at Barrio Dilan, Urdaneta, Pangasinan).
    • The deed of sale executed on that date was not registered with the Registry of Deeds.
  • Mortgage, Foreclosure, and Subsequent Sale
    • On June 10, 1981, Juan Peralta mortgaged the entire lot to Thrift Savings and Loan Association, Inc. (TSLAI) to secure a loan.
    • Due to non-payment of the loan, the mortgage was judicially foreclosed, and TSLAI purchased the property at a foreclosure sale for P62,789.18.
    • TSLAI resold the property on July 15, 1988 for P80,000.00 to petitioner Francisco H. Lu.
  • Subdivision and Overlapping Transactions
    • On August 30, 1989, petitioner subdivided the foreclosed and purchased lot into five lots, one of which became Lot 5582-B-7-D (339 square meters).
    • This particular lot (Lot 5582-B-7-D) was part of the area previously sold by installment to the respondents.
    • The subdivided lot was covered by Transfer Certificate of Title No. 171497.
  • Prior Deed of Sale by Juan Peralta to Respondents
    • On July 30, 1983, Juan Peralta executed a second deed of sale in favor of the respondents concerning the subject lot.
    • Although the respondents paid a total amount of P8,000.00, this deed of sale, like the previous one, was not registered.
  • Dispute and Initiation of Litigation
    • On January 22, 1990, petitioner, through counsel, notified respondents regarding their occupation of the disputed lot.
    • After unsuccessful settlement efforts between the parties, petitioner filed a case on February 26, 1990, alleging that he was the rightful owner of the entire lot, including the disputed portion occupied by the respondents.
    • Petitioner supported his claim by citing a previous regional trial court decision from Urdaneta, Pangasinan, Branch 49 (Civil Case No. U-4399).
  • Respondents’ Counterclaims and Admissions
    • In their answer, respondents claimed that petitioner was a buyer in bad faith, noting that even before purchasing the lot, he was aware that they had already bought and occupied Lot 5582-B-7-D since 1981.
    • They further asserted that petitioner knew about their claim on the property, as his purchase of the foreclosed lot from TSLAI occurred amid a similar dispute involving the whole lot.

Issues:

  • Better Right to the Disputed Property
    • Who holds a superior right of ownership over Lot 5582-B-7-D, notably considering the overlapping transactions and non-registration issues?
    • Does the fact that petitioner registered the purchase of the mother lot give him a preferential claim over the earlier, non-registered sale to respondents?
  • Issues on Bad Faith and Estoppel
    • Was petitioner a purchaser in bad faith, given his knowledge of respondents’ occupation and the prior sale?
    • Can respondents invoke the doctrine of estoppel against petitioner’s claim to ownership?
  • Determination of Consideration/Compensation
    • What is the proper purchase price of the disputed lot, particularly in light of petitioner's plea to set it at P2,000.00 per square meter?
    • Should respondents be exempt from paying petitioner the previously determined amount as a consequence of the errors in the appealed decisions?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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