Case Summary (G.R. No. 138201)
Background and Applicable Law
The 1987 Philippine Constitution and the Civil Code govern this case. Specifically, applicable provisions include Article 1544, which addresses ownership transfer in cases of multiple sales of immovable property.
Factual Background
The contested property originally belonged to the heirs of Juan Canino and Brigida Domasig. Following several transactions, the property came to be sold to Gaudioso Nogales by Julia Deocareza, who had acquired the property through various deeds involving the Canino heirs. Notably, prior to the transactions with the petitioners, the legal rights to the property were still vested in the earlier purchasers, thereby complicating later sales to the petitioners.
Nature of the Trial Court's Decision
The Regional Trial Court of Sorsogon ruled in favor of Gaudioso Nogales, affirming that he was the rightful owner based on the first sale executed by Julia Deocareza. The trial court issued orders for the appellants to vacate the premises and recognized Nogales as the absolute owner with a right to peaceful possession.
Court of Appeals' Affirmation
The Court of Appeals upheld the trial court’s decision, ruling that the petitioners had acquired their titles in bad faith. The appellate court referenced the principle established in Article 1544 regarding the rights of buyers in instances of double sales, emphasizing the primacy of registration and possession.
Petitioners' Claims
The petitioners argued ownership based on their certificates of title and insisted they were good faith purchasers unaware of prior claims. They relied on their registration of sales to establish their rightful ownership over the portions of land they claimed.
Legal Principles on Double Sales
Article 1544 gives preference to the buyer who first recorded the sale in good faith, outlining a hierarchy:
- First to register in good faith
- First in possession in good faith
- Buyer who presents the oldest title in good faith. The court determined that prior registration of the sale with Gaudioso Nogales established his superior claim over the property.
Findings on Good Faith
The appellate court concluded that the petitioners did not act in good faith since they were aware of the existing claims against the property and that the respondent's sale had been recorded before their transactions occurred. The petitioners' reliance on their titles could not override the registration already secured by Nogales.
Final Ruling and Implications
Ultimately, the Supreme Court denied the petitioners' appeal, affirming the decisions of the lower courts. The c
...continue readingCase Syllabus (G.R. No. 138201)
Case Background
- This case involves a petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the December 24, 1998 Decision of the Court of Appeals.
- The appellate court affirmed the trial court's ruling which declared Gaudioso Nogales as the absolute owner of the disputed land.
- The trial court's decision ordered the petitioners to vacate the property and remove their structures within a specified time frame.
Parties Involved
- Petitioners: Francisco Bayoca, Nonito Dichoso, Spouses Pio and Dolores Dichoso, and Erwin Bayoca.
- Respondent: Gaudioso Nogales, represented by Henry Nogales.
Procedural History
- The trial court ruled in favor of Respondent Nogales, declaring him the owner of the property based on a series of transactions leading to his acquisition.
- The petitioners' motion for reconsideration was denied by the Court of Appeals, prompting the current petition to the Supreme Court.
Factual Background
- The property in question originally belonged to the heirs of Juan Canino and Brigida Domasig, who died intestate before 1947.
- Various deeds of sale with rights of repurchase were executed by family members over the years, with Julia Deocareza ultimately acquiring