G.R. No. 174118 - Roman Catholic Church vs. Pante

The Roman Catholic Church (represented by the Archbishop of Caceres) owned a 32-sqm lot (2×16 m) in Barangay Dinaga, Canaman, Camarines Sur.
On September 25, 1992, the Church and Regino Pante executed a Contract to Sell fixing the price at ₱11,200.00 (₱1,120.00 down; balance due by September 25, 1995).

On June 28, 1994, the Church sold a 215-sqm lot (which included the 32-sqm strip) to spouses Nestor and Fidela Rubi. The Rubis then erected a fence blocking Pante’s access.
Pante filed suit to annul the sale to the Rubis insofar as it covered his strip of land. The Church counterclaimed to annul its contract with Pante, alleging fraud by misrepresentation of actual occupancy.
During pre-trial, the parties admitted: the lot’s dimensions; its sale to Pante in 1992; its inclusion in the 1994 sale; and Pante’s representation of occupancy.
On July 30, 1999, the Regional Trial Court annulled the contract with Pante (finding vitiated consent) and upheld the sale to the Rubis (citing Pante’s delayed payment and the Rubis’s prior occupancy).

On May 18, 2006, the Court of Appeals reversed the RTC: it deemed the agreement an absolute sale (ownership passed to Pante), and applied Article 1544 on double sales to award the property to Pante (first in possession in good faith).
The Church filed a Rule 45 petition for review on certiorari before the Supreme Court, contesting (a) the absence of findings on fraud and (b) the CA’s contract characterization and application of double-sale rules.

Whether the Church’s consent to sell was vitiated by Pante’s alleged misrepresentation of actual occupancy, rendering the contract voidable.
Whether the agreement between the Church and Pante is a contract to sell or an absolute contract of sale affecting title transfer.
Whether, under Article 1544 of the Civil Code, Pante or the Rubis spouses first acquired ownership in good faith, given neither sale was registered.