Case Summary (G.R. No. 135038)
Factual Background
The original owners of Lot No. 436-A were Pedro Torrevillas and Lorenzo Atega, who divided the land into northern and southern portions. Several transactions occurred after this division, notably the sale of portions of the lot by Atega to various individuals, including Faustino Fortun and Eduardo Amper. The complexity escalated as Torrevillas and Atega agreed that the reconstituted title would be solely in Torrevillas's name, with claims from Atega and subsequent buyers noted as encumbrances.
Proceedings and Complaints
In 1975, Rolando Tan purchased an 828-square meter portion of Lot No. 436-A-1 from the estate of Ismael Elloso. During 1978, Tan discovered that Leoncio Paderes had erected a structure on the parcel he believed belonged to him. Tan subsequently filed a complaint for accion publiciana against Paderes. Additional complexities arose as other portions of the lot were claimed through subsequent transactions by other respondents.
Regional Trial Court's Decision
The Regional Trial Court ruled in favor of Tan, declaring him the absolute owner of the 828-square meter portion, ordering the demolition of structures from respondents, and the cancellation of conflicting certificates of title. Each defendant was also ordered to pay for attorney's fees and litigation expenses.
Court of Appeals' Reversal
The Court of Appeals later reversed the trial court's decision, dismissing both civil cases filed by Tan. This prompted Tan to seek further review, contending that the appellate court had: (1) abused its discretion in determining legal questions, and (2) deviated from the original findings of ownership established by the trial court.
Legal Principles and Findings
The Supreme Court reinstated the trial court's decision, underscoring the legal principle surrounding double sales and land registration, specifically citing Article 1544 of the Civil Code. The court noted that ownership transfers favor those who first register their claims in good faith. It highlighted that respondents Paderes and Luzon failed to act in good faith, as they had knowledge of Tan’s prior ownership and registration.
Evidence and Good Faith
The Court found that Tan had a valid adverse claim which was duly registered, contradicting the assertion of good faith by respondents who were aware of competing claims against the title they sought to enforce. This awareness rendered their subsequent registrations of title invalid under the principle of good faith required for claimants.
Direction for Further Proceedings
While the Supreme Court reinstated Tan's ownership, it differentiated his case
...continue readingCase Syllabus (G.R. No. 135038)
Case Background
- The case involves a dispute over ownership of a parcel of land known as Lot No. 436-A in Poblacion, Butuan City, originally co-owned by Pedro Torrevillas and Lorenzo Atega.
- The total area of Lot No. 436-A is 9,321 square meters, divided into two portions: Lot 436-A-1 (5,938 sq. meters) owned by Atega and Lot 436-A-2 (3,383 sq. meters) owned by Torrevillas.
- A series of sales occurred involving portions of Lot No. 436-A to various individuals, including Faustino Fortun, Eduardo Amper, and Ismael Elloso, who became the predecessors-in-interest of the petitioner, Rolando Tan.
Ownership Transfers
- Sales by Atega:
- On April 8, 1940, Atega sold 322 square meters to Faustino Fortun.
- On November 2, 1946, Atega sold an additional 56 square meters to Fortun.
- On August 9, 1951, Bernardo Atega sold 450 square meters to Eduardo Amper.
- Subsequent Sales:
- Fortun and Amper later sold a combined area of 828 square meters to Ismael Elloso in 1951.
- Reconstitution of Title:
- Torrevillas and Atega agreed that the reconstituted title would be issued solely in Torrevillas' name, but with a memorandum of encumbrance recognizing claims from Atega and the other vendees, including Elloso.
Legal Proceedings
- The Original Certificate of Title (OCT) No. RO-99 was issued to Torrevillas on March 30, 1955, with annotations regarding the claims of Atega and Elloso.
- On November 24, 1975, Rolando Tan acquired Elloso's 828-square meter portion.
- Dispute