Case Digest (G.R. No. 147072) Core Legal Reasoning Model
Facts:
The case involves Francisco H. Lu as the petitioner and spouses Orlando and Rosita Manipon as respondents. The events transpired when Juan Peralta executed a Deed of Sale by installment in favor of the Manipons on May 9, 1981, concerning a 350 square-meter portion of his larger 2,078 square-meter property situated in Barrio Dilan, Urdaneta, Pangasinan, covered by Transfer Certificate of Title (TCT) No. 137911. This deed, however, was never registered with the Registry of Deeds. Subsequently, on June 10, 1981, Peralta mortgaged the entire 2,078 square-meter lot to Thrift Savings and Loan Association, Inc. (TSLAI) and, after failing to settle the loan, the property was judicially foreclosed and sold to TSLAI. On July 15, 1988, TSLAI resold the lot to Lu, the petitioner, for P80,000.
In the meantime, on July 30, 1983, Peralta executed another unregistered deed of sale, officially transferring the title of the disputed lot, covered by TCT No. 171497, to the Manipons after they had
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)