Case Summary (G.R. No. L-11736-37)
Factual Background
On April 28, 1941, the disputed land was sold by Rosario Costes Dimalanta to Maria G. Dimalanta, documented in public document Exh. "A". Subsequently, on June 12, 1943, the same vendor sold the same property to Toribio Jovellanos and Barbara L. Manuel, as per Exh. "C". None of these transactions were registered under sections 50 and 51 of Act 496 due to the land not being fully segregated. However, on July 21, 1943, Jovellanos and Manuel filed a statement of adverse claim with the Registrar of Deeds and sought a court order to register their deed of sale. In response, on August 4, 1943, Maria Dimalanta filed an opposition and sought to have her deed registered as well.
Concurrent Legal Proceedings
During the pendency of the registration petitions, Maria Dimalanta initiated Civil Case No. 122 in the Court of First Instance of Pangasinan, asserting her ownership of the property and seeking to enjoin the defendants from entering the premises. The two separate but related cases were tried together.
Decision of the Court of First Instance
On July 24, 1956, the Court of First Instance concluded that, assuming both sales were genuine and conducted in good faith, the second purchasers, Jovellanos and Manuel, were the lawful owners of the disputed property due to their priority in recording their adverse claim and their first actual possession of the land.
Appeal and Legal Basis
Maria Dimalanta appealed to the higher court, challenging the lower court's ruling and its purported inconsistencies with established precedents in Quimson vs. Rosete and Sanchez vs. Ramos. The legal principles invoked stem from Article 1473 of the Civil Code of 1889, which governs ownership transfer based on possession and registry.
Application of Civil Code Provisions
The court highlighted that under Article 1473, particularly the second paragraph, the preference is given to the purchaser who first records their sale. Section 110 of the Land Registration Act establishes that an adverse claim record is effective until declared invalid by a competent cour
...continue readingCase Syllabus (G.R. No. L-11736-37)
Case Overview
- The case revolves around a dispute regarding the double sale of a parcel of land, specifically Lot No. 1, Plan PCS-931, Cadastral Case No. 33, located in Dagupan, Pangasinan.
- The land in question is an unsegregated portion of a larger parcel covered by Certificate of Title No. 25515.
- The appeal involves the parties' claims to ownership stemming from two sales of the same property.
Factual Background
- On April 28, 1941, Rosario Costes Dimalanta sold the parcel to Maria G. Dimalanta through a public document (Exhibit "A").
- Subsequently, on June 12, 1943, the same vendor sold the same property to spouses Toribio Jovellanos and Barbara L. Manuel via another public document (Exhibit "C").
- Neither deed of sale was registered under sections 50 and 51 of Act 496 due to the property not being fully segregated.
Legal Proceedings
- On July 21, 1943, Jovellanos and Manuel filed an adverse claim with the Registrar of Deeds, including a copy of their deed of sale, and sought a court order for registration.
- Maria Dimalanta opposed this on August 4, 1943, requesting her deed of sale be accepted for registration and a Certificate of Title be issued to her.
- Dimalanta filed Civil Case No. 122 against Jovellanos and Manuel, seeking declaration