- Petitioner
- Shopper'S Paradise Realty & Development Corporation
- Respondent
- Efren Roque
- Citation
- G.R. No. 148775
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Vitug, J.
- Decided
- January 13, 2004
Summary
This case involves a property lease dispute where Shopper's Paradise leased land from Dr. Felipe Roque, who had previously donated the property to his son Efren through an unregistered deed. The Supreme Court held that the lease was invalid because petitioner had actual knowledge of the prior donation, which rendered the unregistered donation effective against them. The Court emphasized that actual knowledge of an unregistered interest has the same effect as registration regarding that party. Additionally, Dr. Roque lacked authority to lease his son's property without proper authorization. The decision reinforces the principle that parties cannot rely on certificates of title when they have actual knowledge of conflicting unregistered interests, and highlights the importance of agency authority in property transactions.