Alejandro Gabriel v. Spouses Pablo Mabanta

Summary

This Supreme Court case involved a double sale of immovable property under Article 1544 of the Civil Code. Spouses Mabanta first sold their mortgaged lots to Susana Soriano in 1980, who later transferred rights to Alejandro Gabriel in 1984. Subsequently, the same spouses sold one lot to Zenaida Tan-Reyes in 1985, who registered the sale and obtained a new title. The trial court ruled in favor of the Gabriels, finding Tan-Reyes acted in bad faith. The Court of Appeals reversed, but the Supreme Court reinstated the trial court's decision. The Supreme Court emphasized that Article 1544 requires not just prior registration, but registration in good faith. The Court found Tan-Reyes knew of the prior sale through her father's attempt to compensate Gabriel before her purchase, and her registration after the Gabriels filed suit demonstrated bad faith. The decision reinforced that mere registration without good faith cannot defeat prior rights of good faith purchasers in possession.