G.R. No. 205879, 23 April 2014, 723 SCRA 625
The Sylianteng brothers, claims ownership of two parcels of land situated at Pujalte Subdivision, Greenhills, San Juan City. Their claims are based on the Deed of Absolute Sale executed in favor of their mother. They allege that the said lots were acquired by their mother from Luis Pujalte, the previous owner of the property in dispute, as reflected and annotated in the TCT which was sold to them.
Petitioners, herein, claim that Romeo Pujalte was declared by the RTC of Pasig City as the sole heir of Luis Pujalte, which eventually caused the reconstitution of the Mother Title resulting to its cancellation and the issuance of another TCT in his favor. Romeo Pujalte then sold the said properties to herein petitioners.
[Respondents] contend that they have a better right to the lots in question because the transactions conveying the same to them preceded those claimed by [petitioners] as source of the latter’s titles. [Respondents] further assert that [petitioners] could not be considered as innocent purchasers in good faith and for value because they had prior notice of the previous transactions as stated in thememorandum of encumbrances annotated on the titles covering the subject lots. [Petitioners], for their part, maintain that [respondents] acquired the lots under questionable circumstances it appearing that there was no copy of the Deed of Sale, between Emerenciana and Luis Pujalte, on file with the Office of the Register of Deeds.
1. Whether the mother of the Sylianteng brothers validly acquired the subject lots from Luis.
2. Whether the respondents, in tuen, validly acquire the same lots from their mother.
The Court rules in the affirmative, but takes exception to the CA’s and RTC’s application of Article 1544 of the Civil Code.
Reliance by the trial and appellate courts on Article 1544 of the Civil Code is misplaced. The requisites that must concur for Article 1544 to apply are:
(a) The two (or more sales) transactions must constitute valid sales;
(b) The two (or more) sales transactions must pertain to exactly the same subject matter;
(c) The two (or more) buyers at odds over the rightful ownership of the subject matter must
each represent conflicting interests; and
(d) The two (or more) buyers at odds over the rightful ownership of the subject matter must
each have bought from the very same seller.
Obviously, said provision has no application in cases where the sales involved were initiated not by just one but two vendors. In the present case, the subject lots were sold to petitioners and respondents by two different vendors – Emerenciana and Romeo Pujalte (Romeo). Hence, Article 1544 of the Civil Code is not applicable. Nonetheless, the Court agrees with the findings and conclusion of the CA that Emerenciana’s acquisition of the subject lots from Luis and her subsequent sale of the same to respondents are valid and lawful.
Granting that both petitioners and respondents bought the disputed lots in good faith by simply relying on the certificates of the sellers, and subsequently, acquiring titles in their own names, respondents’ title shall still prevail. It is a settled rule that when two certificates of title are issued to different persons covering the same land in whole or in part, the earlier in date must prevail, and, in case of successive registrations where more than one certificate is issued over the land, the person holding a prior certificate is entitled to the land as against a person who relies on a subsequent certificate.37 The titles of respondents, having emanated from an older title, should thus be upheld.
Anent petitioners’ bad faith, this Court finds no persuasive reason to depart from the findings of the CA that petitioners had prior knowledge of the estate proceedings involving the subject lots and that they have notice of the defect in the title of Romeo.
*Case digest by Jhazeel Zhan Jebone, JD-4, Andres Bonifacio Law School, SY 2019-2020