Case Summary (G.R. No. 205879)
Petitioners, Respondents, and Properties
Petitioners challenge CA’s reversal of RTC Pasig judgment; they trace title to TCT Nos. 5888-R (Skunac) and 5889-R (Enriquez). Respondents rest on TCT No. 42369 (Emerenciana) and No. 39488 (Syliantengs) covering Lot 1 (1,250 sqm) and Lot 2 (990 sqm), portions of Mother Title No. 78865.
Key Dates
October 29, 1945 – Original registration of Mother Title in Luis’s name
June 20, 1958 – Deed of Sale from Luis to Emerenciana; TCT No. 42369 issued
June 27, 1983 – Deed of Absolute Sale from Emerenciana to respondents; TCT No. 39488 issued
1992 – Romeo sells to petitioners; TCT Nos. 5760-R, 5888-R, 5889-R issued
November 16, 2007 – RTC decision in favor of petitioners
August 10, 2012 – CA decision in favor of respondents
February 18, 2013 – CA denial of reconsideration
April 23, 2014 – Supreme Court decision
Applicable Law
1987 Philippine Constitution; Civil Code provisions on sale (Arts. 1544, 2208, 2229); Rule 45, Rules of Court; Rules of Evidence (Rules 130–131).
Procedural History
Respondents sued for nullification of petitioners’ titles and recognition of their own. RTC upheld petitioners as buyers in good faith; CA reversed, validated respondents’ titles, annulled petitioners’, and awarded damages and attorney’s fees. Supreme Court granted review on certiorari.
Issues Presented
- Applicability of Civil Code Art. 1544 on double sale of registered land
- Validity of sale from Luis to Emerenciana
- Nullity of TCT No. 42369 in Emerenciana’s name
- Lawful acquisition by petitioners from Romeo
- Entitlement to damages and attorney’s fees
Findings of Fact and Burden of Proof
The Supreme Court found conflicting RTC and CA fact-findings and invoked exceptions to the rule against reviewing factual issues on certiorari. Under civil burdens, respondents proved valid chain of title from Luis to Emerenciana to themselves.
Validity of Sales to Respondents
Deed of Sale (June 20, 1958) was duly notarized, giving it public-document status with presumption of regularity. Certified notarial register entry confirmed regular notarization. Official receipts proved registration of sale in Quezon City. Duplicate originals are equally authentic under Rule 130.
Inapplicability of Civil Code Article 1544
Article 1544 governs double sales by the same vendor; here, Emerenciana and Romeo were different vendors. Thus, the CA and RTC erred in applying it.
Registration and Annotations on Title
Mother Title bore Entry No. P.E. 4023—partial cancellation for Lots 1 and 2 and issuance of TCT No. 42369 to Emerenciana. This memorial annotation, coupled with the Torrens system’s principle of indefeasibility subject to recorded encumbrances, put all subsequent acquirers on constructive notice.
Validity of Petitioners’ Title
Romeo never owned the lots: they were sold in 1958 and excluded from Luis’s estate inventory and partition. Estate court denied Romeo’s sale approval. A criminal conviction for use of falsified documents discredited his heirship claim, invoking nemo dat quod non habet. Petitioners thus acquired no title from an unauthorized seller.
Good Faith and Notice
Petitioners’ reliance on Romeo’s titles was not in good faith; TCT No. 5760-R carried the same P.E. 4023 a
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Facts
- The subject properties consist of two parcels in Block 2, Pujalte Subdivision, Greenhills, San Juan City: Lot 1 (1,250 sqm) and Lot 2 (990 sqm), originally under Mother Title TCT No. 78865 (October 29, 1945).
- Emerenciana Sylianteng acquired both lots from Luis A. Pujalte by a Deed of Sale dated June 20, 1958 (annotated Entry No. P.E. 4023) and was issued TCT No. 42369.
- Emerenciana sold the same lots to her sons, Roberto S. Sylianteng and Caesar S. Sylianteng, by Deed of Absolute Sale dated June 27, 1983, leading to issuance of TCT No. 39488 in their names.
- Romeo N. Pujalte was later declared sole heir of Luis in Special Proceedings No. 3366; the Mother Title was reconstituted, TCT No. 5760-R issued in Romeo’s name, and subsequently split into TCT No. 5888-R (Lot 1 in favor of Skunac Corporation) and TCT No. 5889-R (Lot 2 in favor of Alfonso F. Enriquez) upon Romeo’s 1992 sale to them.
- Respondents (the Sylianteng brothers) claim priority of ownership based on their 1983 purchase; petitioners (Skunac and Enriquez) claim valid title through Romeo’s later registration.
Procedural History
- Civil Case Nos. 63987 and 63988 filed before the Regional Trial Court (RTC) of Pasig City, Branch 160.
- Petitioners answered; Romeo intervened; respondents resisted.
- RTC rendered judgment on November 16, 2007, in favor of Skunac and Enriquez, canceling TCTs in respondents’ names and validating petitioners’ titles.
- Respondents appealed to the Court of Appeals (CA) in CA-G.R. CV No. 92022.
- CA Decision (August 10, 2012) reversed the RTC, nullified petitioners’ TCTs, upheld respondents’ titles, and awarded moral and exemplary damages (P500,000 each), attorney’s fees (P250,000), and costs.
- CA denied petitioners’ motion for reconsideration on February 18, 2013.
- Petitioners filed a Rule 45 petition for review on certiorari before the Supreme Court.
Issues
- Whether the CA misapplied Article 1544 of the Civil Code on double sale of registered land.
- Whether respondents failed to prove the sale from Luis Pujalte to Emerenciana Sylianteng.
- Whether TCT No. 42369 in Emerenciana’s name is null and void.
- Whether petitioners validly acquired the lots from Romeo Pujalte, the sole heir of Luis.
- Whether moral and exemplary damages, attorney’s fees, and costs were improperly awarded against petitioners.
Ruling of the Regional Trial Court
- Declared TCT No. 42369 (Emerenciana) and TCT No. 39488 (respondents) null and void.
- Recognized petitioners as buyers in good faith for value.
- Validated TCT No. 5888-R (Skunac) and TCT No. 5889-R (Enriquez).
- Dismissed complaint-in-intervention; imposed costs on respondents.
Ruling of the Court of Appeals
- Found respondents’ titles (TCT Nos. 42369, 39488) valid an