Clara M. Balatbat v. Court of Appeals

Summary

This case involves a double sale of immovable property under Article 1544 of the Civil Code. Aurelio Roque sold his 6/10 share in a Manila property to the Repuyan spouses in 1980, who annotated an adverse claim. The same property was later sold to Clara Balatbat in 1982 through a court-ordered partition sale. The Supreme Court applied the rules on double sale, holding that the Repuyans had superior rights having first recorded their adverse claim in good faith on July 21, 1980, while Balatbat only filed a lis pendens much later. The Court found Balatbat was not a buyer in good faith as she failed to investigate the property's encumbrances despite the pending litigation and adverse claim annotation. The decision clarifies that ownership passes upon constructive delivery through public instruments even without full payment, and emphasizes the importance of good faith and proper investigation in property transactions.