Spouses Adiel de La Cena v. Spouses Jose Briones

Summary

This case involves a double sale of immovable property where the Arevalo spouses first sold a portion of their lot to the Briones spouses in 1977, then later sold the entire lot to the de la Cena spouses in 1979. The Supreme Court affirmed the Court of Appeals ruling that despite the de la Cenas registering their purchase first, they were not buyers in good faith because they knew the Briones spouses were in possession and claiming ownership but failed to inquire about their rights. The Court applied Civil Code Article 1544 on double sales, emphasizing that registration in bad faith after knowledge of a previous sale confers no rights. The decision highlights the importance of good faith in property transactions and the duty of prospective buyers to investigate the rights of parties in actual possession of real property.