Case Summary (G.R. No. 170073)
Factual Antecedents
Belen Consing Lazaro originally sold a 400 sq. m. portion of Lot 11-E to Daisy Teresa Cortel Magallanes under a "Contract to Sell" in 1979. This sale was completed with the execution of a "Deed of Definite Sale" in 1980. Magallanes subsequently took possession of the land, fenced it, and constructed a hut. Conflicts arose when Lazaro sold the same property to her niece Lynn Lazaro and husband Rogelio Natividad in 1981, resulting in the issuance of a new title. Magallanes filed adverse claims and a lis pendens concerning the property, which led to litigation going through the courts until the matter reached the appellate level.
Ruling of the Regional Trial Court
On September 6, 1996, the Iloilo Regional Trial Court ruled in favor of the respondents, declaring them the rightful owners of Lot 11-E-8-A. The court emphasized that Magallanes’ prior purchase and subsequent actions to secure her ownership were valid. The sale of the same land to the Spouses Natividad was rendered ineffective because Magallanes was already in possession, and thus, the petitioners could not claim to be buyers in good faith despite their registration of the title.
Ruling of the Court of Appeals
The Court of Appeals affirmed the trial court's decision on June 6, 2005, reinforcing that the Spouses Natividad were not buyers in good faith given the prior sale to Magallanes and her actions in possessing the land. The appellate court also recognized the existence of the lis pendens at the time of petitioners' purchase, implicitly arguing that this notice undermined any claims of good faith as buyers.
Issues Raised by Petitioners
The petitioners presented several arguments including claims that the subject of the dispute was Lot 11-E-8-A, while Magallanes was only claiming Lot 11-E-8-B. They contested that the issue of good faith could not be determined without allowing the Spouses Natividad to defend themselves as buyers. Furthermore, they argued that the cancellation of the lis pendens notice post-sale indicated they were buyers in good faith and contested the imposition of attorney's fees against them.
Respondents’ Arguments
Respondents asserted that they maintained possession and ownership of Lot 11-E-8-A, countering petitioners' claim of ownership over Lot 11-E-8-B. They noted that Magallanes’ claim to Lot 11-E-8-A was substantiated by clear evidence of possession and improvements made to the property.
Our Ruling
The decision confirms that Magallanes, as the first buyer and possessor, had superior
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Case Reference
- Citation: 647 Phil. 655; 107 OG No. 35, 4171 (August 29, 2011); 107 OG No. 43, 5395 (October 24, 2011)
- G.R. No.: 170073
- Decision Date: October 18, 2010
- Division: First Division
- Judge: Del Castillo, J.
Background
- The case involves a dispute over ownership of a 400 square meter parcel of land identified as Lot 11-E-8-A in Iloilo City, with key players including:
- Petitioners: Spouses Ramy and Zenaida Pudadera
- Respondents: Ireneo Magallanes and the late Daisy Teresa Cortel Magallanes, represented by their children
- The primary issue revolves around good faith in property transactions and the implications of prior possession.
Factual Antecedents
- Belen Consing Lazaro owned Lot 11-E, which was subdivided and partially sold to several buyers, including Daisy Teresa Cortel Magallanes.
- Magallanes purchased a 400 sq. m. portion of Lot 11-E from Lazaro under a "Contract to Sale" and subsequently a "Deed of Definite Sale."
- Notably, Magallanes fenced the lot and constructed a nipa hut, asserting her ownership.
- Complications arose when Lazaro sold the same lot to the Spouses Natividad, who later sold it to the petitioners, Ramy and Zenaida Pudadera.
- The lot had a lis pendens notice due to ongoing litigation regarding ownership, which petitioners failed to investigate before purchasing.
Ruling of the Regional Trial Court (RTC)
- The RTC declared Magallanes' heirs as the rightful owners of Lot 11-E-8-A, emphasizing:
- Magallanes' immediate possession and improvements on the property.
- The sale to Spouses Natividad did not confer rights as Magallanes was t