Case Summary (G.R. No. 96306)
Core Issue
The primary issue involves whether prescription bars the action of the first vendees to annul the transfer certificate of title obtained by the second vendee, who was aware of the initial sale and the possession of the first vendees.
Factual Background
Jose de los Santos sold a portion of his property to private respondents (Flores and Bareja) in 1961. In 1963, he sold the remaining portion of the property to petitioner Berico, who was aware of the earlier sale and the respondents' possession. Despite this knowledge, Berico registered the property in 1968 and obtained a new title.
Trial Court Findings
The trial court ruled that Berico acted in bad faith when he registered the property, given his awareness of the private respondents' prior sale and possession. It concluded that Berico's registration was ineffective under Article 1544 of the Civil Code, emphasizing that good faith is a fundamental requirement for property registration.
Appeal and Decision
Upon appeal, the Court of Appeals upheld the trial court's ruling, reiterating that Berico's registration was invalid due to his bad faith. It clarified that the private respondents' action for annulment was not barred by prescription because they only discovered the fraud in 1978, within the four-year prescription period for fraud-related actions.
Legal Principles Applied
- Article 1544 of the Civil Code governs the rights in cases of double sale; the ownership belongs to the party who in good faith first recorded the sale.
- Bad Faith in Registration affects the validity of the title, as mere registration without good faith does not confer ownership rights.
- The concept of prescription was addressed, with the Court emphasizing that the registration resulting from bad faith does not constitute constructive notice.
Conclusion and
...continue readingCase Syllabus (G.R. No. 96306)
Case Background
- The case revolves around a dispute over the ownership of a parcel of land following a double sale.
- Jose de los Santos was the original owner of a 98,254 square-meter parcel of land known as Lot No. 785, located in Balo-Andang, San Ramon, San Pascual (now Claveria), Masbate.
- On October 31, 1961, Jose de los Santos sold a portion of the land to private respondents Ciriaco Flores and Felisa Bareja, who subsequently took possession and declared it for taxation.
- On November 26, 1963, Jose executed another deed of sale, selling the same parcel to petitioner Lorenzo Berico, who was later aware of the prior sale to Flores and Bareja.
Legal Issue
- The primary legal question is whether the action by the first vendees (Flores and Bareja) against the second vendee (Berico) for annulment of the transfer certificate of title is barred by prescription given that Berico had knowledge of the prior sale and recognized the first vendees' possession.
Findings of the Trial Court
- The trial court ruled in favor of Flores and Bareja, stating that Berico acted in bad faith by registering his title despite knowing of the earlier sale.
- The trial court found that Berico's registration was ineffective under Article 1544 of the Civil Code, which emphasizes the necessity of good faith in property sales.
- The court reiterated that the private respondents, having taken possession first in good faith, were entitled to own