Case Summary (G.R. No. 209786)
Background Facts
In July 1992, Cattleya Land, Inc. initiated the process to purchase nine lots from spouses Troadio and Asuncion Tecson. After confirming the titles were defect-free, the respondent executed a Deed of Conditional Sale on November 6, 1992, followed by a Deed of Absolute Sale executed on August 30, 1993. Both deeds were registered with the Register of Deeds, although trouble arose due to an attachment notice from a pending civil case, which was eventually resolved.
Registration Conflicts
On January 23, 1995, Carmelita Fudot presented a deed of sale allegedly executed by the Tecsons in her favor on December 19, 1986, for registration. While responding to her application, Cattleya Land, Inc. protested her registration due to their existing sales agreements. Despite this, the Register of Deeds subsequently registered Fudot's deed, issuing a new title in her name.
Trial Court Proceedings
On May 5, 1995, Cattleya Land, Inc. filed a Complaint for Quieting of Title and other reliefs in the Regional Trial Court. Asuncion Tecson intervened in the case, asserting that her signature on Fudot’s deed of sale was forged and claiming the sale was null. The trial court ruled in favor of Cattleya Land, confirming that Fudot's deed was invalid due to forgery and granting a quiet title to Cattleya Land.
Court of Appeals Decision
Upon appealing to the Court of Appeals, Fudot contended that the rule on double sale applied, but the appellate court denied her appeal. The decision emphasized that since Fudot's sale was void due to forgery, no double sale existed. The Court of Appeals also underscored that Cattleya Land's registration of its claim was in good faith, restoring its rights to the property.
Issues Presented
Petitioner Fudot raised several issues:
- The determination of who possessed a better right to the property between herself, claiming first sale rights, and Cattleya Land, the second buyer.
- Whether a buyer failing to demand the delivery of the owner’s duplicate certificate could still be deemed a buyer in good faith.
- The applicable law governing situations of registration, highlighting differing views between the Civil Code and P.D. No. 1529.
Arguments from the Parties
Fudot argued that she was the first buyer in good faith, possessing the owner’s copy of the title, while alleging that Cattleya Land had knowledge of title issues, disputing its claim to good faith. Cattleya Land countered that Fudot's claims were irrelevant, given her reliance on a fraudulent transaction, hence, nullifying her position in the registration hierarchy.
Ruling on Ownership and Registration
The Supreme Court held Fudot’
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Case Overview
- This case revolves around a petition filed by Carmelita Fudot (petitioner) to nullify the Decision and Resolution of the Court of Appeals dated April 28, 2005, and January 11, 2006, respectively, in C.A.G.R. CV No. 73025.
- The appellate court ruled that Cattleya Land, Inc. (respondent) had a superior right over a parcel of land located in Doljo, Panglao, Bohol.
Factual Background
- Cattleya Land, Inc. sought to purchase nine lots from spouses Troadio and Asuncion Tecson in July 1992.
- The titles were found to be free of defects and the respondent executed a Deed of Conditional Sale on November 6, 1992, followed by a Deed of Absolute Sale on August 30, 1993.
- The Register of Deeds delayed the registration of the Deed of Absolute Sale due to an attachment related to a civil case, which was later lifted after a compromise agreement.
- On January 23, 1995, the petitioner registered a deed of sale executed by the Tecsons in her favor on December 19, 1986, and the Register of Deeds issued a new title in her name the following day.
- Respondent filed a Complaint for Quieting of Title, Recovery of Ownership, and Cancellation of Title with Damages in May 1995.
Trial Court Proceedings
- Asuncion Tecson intervened, claiming her signature on petitioner’s deed of sale was forged and asserting she had not consented to the sale.
- The trial court ruled in favor of the respondent, declaring the sale to petitioner invalid due to forgery and recognizing respondent's good faith in their purchase.
- It also orde