Case Digest (G.R. No. 172060)
Facts:
In Spouses Noel and Julie Abrigo vs. Romana de Vera (G.R. No. 154409, June 21, 2004), the petitioners, spouses Noel and Julie Abrigo, and respondent Romana de Vera contended over a house and lot in Banaoang, Mangaldan, Pangasinan. The property was originally registered under the Torrens system to Gloria Villafania by free patent (OCT No. P-30522, March 15, 1988), later reissued as TCT No. 212598 (April 11, 1996). On May 27, 1993, Villafania sold the parcel to Rosenda Tigno-Salazar and Rosita Cave-Go, who secured their own tax declaration and later sold it to the Abrigos (petitioners) on October 16, 1997, and registered the deed under Act 3344. Unknown to them, on October 23, 1997, Villafania executed a second sale to De Vera, who examined the Torrens title, paid full value, and registered her deed under the Torrens system, resulting in TCT No. 22515. The Abrigos filed an ejectment suit before the Municipal Trial Court of Mangaldan, which was dismissed by agreement. They then proCase Digest (G.R. No. 172060)
Facts:
- Parties and Property
- Gloria Villafania was the registered owner of a house and lot in Banaoang, Mangaldan, Pangasinan, originally covered by Tax Declaration No. 1406 and Torrens titles OCT No. P-30522 (free patent) and later TCT No. 212598.
- Spouses Noel and Julie Abrigo and private respondent Romana de Vera each claimed ownership through successive deeds of sale, leading to competing registrations.
- Chain of Conveyances and Registrations
- May 27, 1993: Villafania sold the property to Rosenda Tigno-Salazar and Rosita Cave-Go; sale was registered under Act 3344 on June 18, 1993. A compromise decree gave Villafania one year to repurchase; she failed to do so.
- October 16, 1997: Tigno-Salazar and Cave-Go sold to the Abrigos; registered under Act 3344 on October 30, 1997.
- October 23, 1997: Villafania sold the same property to Romana de Vera, who registered the sale under the Torrens system, resulting in TCT No. 22515 in her name.
- Preceding Litigation and Appeals
- November 12, 1997: De Vera filed a forcible entry case against the Abrigos; dismissed February 25, 1998 upon the parties’ agreement to await resolution of the instant suit.
- November 21, 1997: The Abrigos filed an action before the Regional Trial Court (RTC) seeking annulment of De Vera’s title, injunctions and damages; RTC’s January 4, 1999 decision awarded the property and damages to the Abrigos.
- Court of Appeals (CA) Decisions:
- November 19, 2001 original decision—ruled De Vera’s title void and dismissed both appeals.
- March 21, 2002 amended decision—held De Vera an innocent purchaser in good faith, declared her the rightful owner, and awarded damages against Villafania and the Abrigos; denial of reconsideration affirmed July 22, 2002.
Issues:
- Is the deed of sale from Gloria Villafania to Romana de Vera valid?
- Is De Vera a purchaser for value in good faith?
- Between the Abrigos and De Vera, who has the better right to the property?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)