Case Summary (G.R. No. 106042)
Factual Background
On August 10, 1983, petitioners acquired a parcel of land from Maria dela Cruz vda. de Santiago and Jose Santiago, heirs of Dionisio Santiago. The land, initially registered in Dionisio Santiago's name, was sold to petitioners through an extrajudicial settlement and absolute sale for P55,420. Following the sale, a new Transfer Certificate of Title (TCT No. 105231) was issued in favor of the petitioners.
Legal Proceedings Initiated by Petitioners
On February 27, 1984, after the respondents failed to vacate the premises, petitioners' counsel demanded that the Salvador spouses show proof of their right to occupy the property. Subsequently, on July 1, 1988, petitioners filed a complaint for recovery of possession in the Regional Trial Court of Malabon, seeking to evict the respondents.
Respondents' Claim and First Instance Judgment
Respondents claimed ownership based on installments paid for half of the property beginning in December 1974, and alleged that they also acquired another half of the land in 1979 through payments made to Benjamina Magalong, wife of Dionisio Santiago. The trial court ultimately dismissed the petitioners' claim, finding that there was a double sale of the property. The court applied Article 1544 of the New Civil Code, concluding that the respondents, having possessed the land since 1970, had a preferential right over petitioners.
Analysis of Bad Faith
The trial court noted that petitioners acted in bad faith by failing to inquire about the rights of the respondents, who were in actual possession of the property. Testimony indicated that petitioners relied solely on the statements of the vendors regarding the respondents' right to occupy the land, without directly addressing the respondents, despite being aware that they had been living there since 1970. The court stressed the obligation of a buyer to make inquiries when the property is in the possession of another party.
Appeal to the Court of Appeals
On appeal, petitioners continued to challenge the trial court's conclusion of bad faith, asserting that their inquiries were sufficient for good faith determination. However, the Court of Appeals upheld the trial court’s decision, affirming that petitioners failed to exercise due diligence required to ascertain the title of the property. The appellate court reiterated that merely checking the title is insufficient when dealing with vendors who are not the registered owners.
Legal Interpretation of Article 1544
Article 1544 of the New Civil Code establishes that in cases of double sale, priority is given to the person who first took possession in good faith or, for immovable properties, to the one who firs
...continue readingCase Syllabus (G.R. No. 106042)
Background of the Case
- The case revolves around a dispute over a parcel of land located in Barrio Maysilo (now Santolan), Malabon, originally registered under Dionisio Santiago.
- Petitioners, spouses Alfredo Valdez and Rufina Bautista, purchased the land on August 10, 1983, from Maria dela Cruz vda. de Santiago and Jose Santiago through a deed of extrajudicial settlement with absolute sale.
- The petitioners paid a total of P55,420.00, leading to the issuance of Transfer Certificate of Title (TCT) No. 105231 in their names.
Factual Circumstances Leading to the Dispute
- After the purchase, petitioners demanded that private respondents, spouses Donald and Cresencia Salvador, vacate the premises in a letter dated February 27, 1984.
- The Salvador spouses claimed ownership of the property, stating they bought it in installments from Dionisio Santiago—half on December 20, 1974, and the other half on October 20, 1979.
- They asserted that their payments were completed by October 15, 1981, and maintained uninterrupted possession since 1970.
Proceedings in the Regional Trial Court
- Petitioners filed a complaint for recovery of possession on July 1, 1988, after private respondents did not vacate the premises.
- The trial court ruled on February 28, 1991, dismissing the petitioners’ complaint for lack of merit and recognizing private respondents' preferential rights over half of the property.
- The court determined there was a double sale of the property and that the Salvador spouses had a better claim due to their prior possession.