Spouses Avelino v. Spouses Celedonio

Summary

This case involved competing ownership claims over a parcel of land in Leyte. Spouses Salera purchased the property from the heirs of Brigido Tonacao, while Spouses Rodaje bought the same property from Catalino Tonacao, Brigido's father. The RTC declared Saleras as rightful owners, finding that Catalino lacked authority to sell as the property belonged to Brigido's heirs. The Court of Appeals reversed, applying Article 1544 on double sales and favoring Rodajes who registered first. The Supreme Court ultimately reinstated the RTC decision, ruling that Article 1544 was inapplicable since it involves single vendor scenarios, not different vendors selling the same property. The Court found Rodajes acted in bad faith, knowing the property was declared under Brigido's name, and that Catalino had no valid title to convey. Evidence showed Saleras had prior actual possession, having built a house in 1981-1984.