Rufina Bautista v. Hon. Court of Appeals

Summary

This case involves a double sale of a 326 sq.m. property in Malabon originally owned by Dionisio Santiago. The property was first sold to Salvador spouses in 1974 who took possession but never registered the sale. After Santiago's death in 1982, his heirs sold the entire property to Valdez spouses in 1983, who registered the sale. The Supreme Court applied Article 1544 of the Civil Code and ruled that while registration normally gives preference, it must be coupled with good faith. The Court found Valdez spouses were purchasers in bad faith because they failed to inquire from the actual possessors (Salvador spouses) about their rights, despite knowing of their long-standing possession and living nearby. The Court emphasized that when buying from heirs rather than the registered owner, buyers must exercise higher prudence and investigate the rights of actual possessors. The decision affirmed Salvador spouses' right to half the property while awarding the other half to Valdez spouses.