- Petitioner
- Spouses Mariano S. Tanglao
- Respondent
- Spouses Corazon S. Parungao
- Citation
- G.R. No. 166913
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Sandoval-Gutierrez, J.
- Decided
- October 5, 2007
Summary
This case involves a double sale of real property where Spring Homes Subdivision sold the same lots to two different buyers. Spouses Parungao purchased seven lots in 1992, made improvements, and remained in possession, but Spring Homes failed to deliver titles. In 1997, Spring Homes sold two of the same lots to spouses Tanglao who obtained titles and forcibly took possession. The Supreme Court applied Article 1544 of the Civil Code governing double sales of immovable property, ruling that Tanglao were not buyers in good faith since the existing occupancy and improvements should have alerted them to adverse claims. The Court held that Parungao, being first in possession in good faith, have superior ownership rights under the principle of prius tempore, prius jure (first in time, stronger in right).