Spouses Mario Ong v. Spouses Ergelia Olasiman

Summary

This case involves competing claims over unregistered land in Negros Oriental. Paula Verzano sold the land to her niece Bernandita in 1992, then died later that year. Paula's brother Demetrio fraudulently executed an extrajudicial settlement claiming sole heirship and sold the same land to the Ongs in 1995. Bernandita subsequently sold to the Olasimans in 1996. The RTC initially favored the Ongs under Article 1544's double sale provision, but the Court of Appeals and Supreme Court reversed, finding that Paula's 1992 sale to Bernandita had already transferred ownership. Since Paula no longer owned the land at death, Demetrio inherited nothing and could convey nothing to the Ongs. The Supreme Court emphasized that Article 1544 applies only when the same vendor sells to different buyers, not when different vendors are involved. The decision affirmed the Olasimans' superior title through their predecessor Bernandita.