Case Summary (G.R. No. 202052)
Applicable Law
The primary legal provision in question is Article 1473 of the Civil Code, which dictates the rules regarding ownership of movable and immovable property in cases of multiple transfers to different vendees. The article establishes that ownership of personal property goes to the first possessor in good faith, while ownership of real property is awarded to the first purchaser who records the sale in the Registry of Deeds. If neither is recorded, good faith possession prevails, or, in absence of possession, the party with the oldest title prevails if acting in good faith.
Factual Background
The litigation centers on a parcel of land that underwent two transfers: first, to Arcadio M. Bolo on December 19, 1929, through a private document, and subsequently to Simeon B. Paz on April 29, 1939, via a duly notarized deed of cession that was registered in the Camarines Sur Registry of Deeds. The lower court ruled in favor of Paz based on the registered deed, asserting its priority over the unregistered private sale to Bolo.
Appellant's Argument
Arcadio M. Bolo contested the lower court's decision, alleging that Simeon B. Paz acted in bad faith when he acquired the land. Bolo argued that Paz was aware of the prior sale of the property to him and presented evidence to support this claim, including statements from a cross-complaint Paz had filed wherein he referred to the earlier transfer of the property by Lucio Botor to Bolo. Such claims indicated that Bolo had paid a debt of Botor to a third party, which Botor compensated with the land.
Court's Analysis
The court emphasized the foundational principle of good faith within the context of Article 1473. It concluded that Simeon B. Paz did not act in good faith, given his knowledge of the previous sale to Arcadio M. Bolo. The court noted that such knowledge nullified any claim Paz had to the property since his acquiring the land did not meet the good faith requirement. Thus, the deed of cession
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Case Citation
- Jurisprudence: 81 Phil. 16
- C.A.- G.R. No. L-650
- Date of Decision: May 14, 1948
Parties Involved
- Plaintiffs and Appellees: Nicanora Bernas, Eligia Botor, Juana Botor, and Primo Botor
- Defendant and Appellant: Arcadio M. Bolo
- Third Party Appellees: Maria M. Paz et al.
Legal Framework
- The case revolves around the interpretation of Article 1473 of the Civil Code of the Philippines, which addresses the transfer of ownership in instances where the same property has been sold to multiple parties.
- The article stipulates:
- For personal property, ownership transfers to the first possessor in good faith.
- For real property, ownership goes to the purchaser who first records it in the Registry of Deeds.
- If not recorded, ownership belongs to the first possessor in good faith or, if there is no possession, to the holder of the oldest title, provided good faith is established.
Factual Background
- The land in question was sold twice by its former owner, Lucio Botor:
- First Sale: On December 19, 1929, to Arcadio M. Bolo through a private document of sale.
- Second Sale: On April 29, 1939, to Simeon B. Paz via a deed of cession that was ratified by a notary public and registered in