G.R. No. L-2377 - Republic vs. Vda. de Guido

In July 1992, Cattleya’s counsel investigated the status of an 8,805-sq.m. parcel in Doljo, Panglao, Bohol (TCT No. 17655) registered to spouses Troadio B. Tecson and Asuncion Ortaliz-Tecson; only an attachment in Civ. Case No. 3399 appeared on the title.
On November 6, 1992, Cattleya and the Tecson spouses executed a Contract of Conditional Sale (Entry No. 83422). On August 30, 1993, they executed a Deed of Absolute Sale (Entry No. 87549), but the Register of Deeds refused annotation due to the attachment.

The attachment was later lifted, yet Cattleya could not finalize registration because the owners’ copy of TCT No. 17655 remained with the Tecson spouses, who falsely claimed it was destroyed by fire.
Cattleya learned the title had been delivered to petitioner Taina Manigque-Stone under a deed executed by the Tecson spouses in favor of Taina.

In December 1985, Taina’s common-law husband Michael Stone (an American) negotiated with Col. Tecson and made downpayments totaling US$1,750 (₱35,000) toward a portion of the beach lot.
On June 1, 1987, Tecson executed a Deed of Absolute Sale in Taina’s name; subsequent payments by Michael and delivery of TCT No. 17655 followed. Taina married Michael in October 1986.

On April 25, 1994, Taina filed a Notice of Adverse Claim after learning of a petition for a duplicate title. On February 8, 1995, she registered her Deed of Absolute Sale and obtained TCT No. 21771 in her name.
Cattleya filed RTC Civil Case No. 5782 for quieting of title, cancellation of TCT No. 21771, and recovery of possession against Taina. Taina impleaded the Tecson spouses as third-party defendants.

The RTC held the Tecson-to‐Michael/Taina sale void for violating the constitutional ban on alien land ownership, declared Cattleya’s sale valid by prior registration (Oct. 4, 1993), and ordered cancellation of Taina’s title. It awarded Taina P77,000 recovery from the Tecson spouses plus damages.
On August 16, 2010, the CA affirmed with modifications: it quashed Taina’s title, upheld Cattleya’s ownership, and ordered registration of Cattleya’s Deed of Absolute Sale. The CA also enforced the RTC’s award against the Tecson spouses. Denial of Taina’s motion for reconsideration followed on February 22, 2011.
Taina appealed to the Supreme Court, raising questions on dummy sale, constitutional violation, cure by marriage/registration, and the double‐sale rule.

Whether the sale of the subject property to Michael Stone through petitioner, as his “dummy,” is void under Section 7, Article XII of the Constitution.
Whether the rule on double sale (Art. 1544, Civil Code) applies when the first sale is constitutionally void.
Whether petitioner’s subsequent marriage to Michael Stone and registration of the title in her name cures the constitutional infirmity.
Whether defective notarization and dubious delivery of title invalidate petitioner’s claimed transfer.