Facts:

The case involves a dispute over a parcel of land located in Barangay Calindagan, Dumaguete City, originally owned in common by the Orbeta family, specifically Serbio, Anfiano, Engracia, Carmela, Manuel, Teresito, Corazon, Segundina, and Leonardo Orbeta. The petitioners, Ernesto and Rosita Manlan, purchased a 500 square meter portion of the property from Manuel Orbeta on May 5, 1983, for P30,000.00, and were allowed to occupy the land after paying an advance of P15,000.00. On October 21, 1986, the remaining co-owners, represented by Emiliana Villamil Orbeta after Manuel's death, executed a Deed of Absolute Sale (DOAS) selling a 714 square meter portion of the same property to Ricardo and Zosima Beltran, the respondents. Subsequently, on November 20, 1990, the respondents acquired the remaining 500 square meters from the Orbetas, which was registered under Transfer Certificate of Title (TCT) No. 20152 on January 28, 1991. When the respondents demanded that the petitioners ...

Facts:

Background of the Case

The case involves conflicting claims over a 1,214 square meter (sq.m.) parcel of land in Barangay Calindagan, Dumaguete City, originally owned in common by the Orbetas (Serbio, Anfiano, Engracia, Carmela, Manuel, Teresito, Corazon, Segundina, and Leonardo).

Petitioners' Claim

On May 5, 1983, Spouses Ernesto and Rosita Manlan (petitioners) bought a 500 sq.m. portion of the land from Manuel Orbeta for P30,000.00. They paid an advance of P15,000.00 and were allowed to occupy the property.

Respondents' Claim

On October 21, 1986, the Orbetas (except Manuel, who was deceased) executed a Deed of Absolute Sale (DOAS) conveying a 714 sq.m. portion to Spouses Ricardo and Zosima Beltran (respondents). On November 20, 1990, respondents bought the remaining 500 sq.m. from the Orbetas, evidenced by another DOAS. The property was registered in respondents' name under Transfer Certificate of Title (TCT) No. 20152 on January 28, 1991.

Dispute and Legal Action

Respondents demanded petitioners vacate the property, but petitioners refused. After failed conciliation at the barangay level, respondents filed an action for quieting of title and recovery of possession. Petitioners countered, alleging they bought the land from Manuel and Serbio Orbeta in 1983 and claimed the 1990 DOAS was fraudulent due to Serbio's death at the time of notarization.

Issue:

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Ruling:

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Ratio:

1. Double Sale Rule: Article 1544 applies only when the same property is sold by a single vendor to different vendees. Here, the sales were made by different vendors (Manuel Orbeta vs. all Orbetas), so the rule does not apply.

2. Defective Notarization: A defective notarization does not invalidate a sale. It merely reduces the document to a private instrument, which can still be enforced if proven authentic. Respondents provided sufficient evidence to validate the 1990 DOAS.

3. Collateral Attack: A Torrens title cannot be collaterally attacked. Petitioners' counterclaim did not specifically seek reconveyance or annulment of the title, making it an impermissible collateral attack.

Conclusion:

The Supreme Court upheld the CA and RTC rulings, affirming respondents' ownership of the property. Petitioners' claims were dismissed for lack of merit.