Abrigo v. Vera

Summary

This Supreme Court case involved a double sale of immovable property where Gloria Villafania sold the same land to two different sets of buyers. The first sale (1993) was to Tigno-Salazar and Cave-Go, who later sold to petitioner spouses Abrigo (1997). The second sale (1997) was directly from Villafania to respondent De Vera. Both transactions were registered - petitioners under Act 3344 and respondent under the Torrens system. The Supreme Court applied Article 1544 of the Civil Code on double sales and ruled that since the property was already under the Torrens system, registration under the proper system (Torrens) prevails over registration under Act 3344. The Court found De Vera to be a purchaser in good faith who relied on a clean Torrens title, thus giving her superior right to the property. The decision reinforces the principle that registration must be done in the proper registry to effectively bind land, and that good faith registration under the Torrens system takes precedence over registration under other systems when the property is already Torrens-registered.