Petitioner
The Roman Catholic Church
Respondent
Regino Pante
Citation
G.R. No. 174118
Court
Supreme Court
Division
Second Division
Ponente
Brion, J.
Decided
April 11, 2012

Summary

The Roman Catholic Church sold a 32-square meter strip of land to Regino Pante in 1992, then subsequently sold a larger lot that included the same property to the Rubi spouses in 1994, creating a double sale situation. The Church sought to annul its contract with Pante, claiming fraud through misrepresentation about his occupancy status. However, the Supreme Court found no fraudulent misrepresentation, noting that the narrow strip could only serve as a passageway and that the Church was aware of this fact, as evidenced by the contract's sketch plan labeling it as 'RIGHT OF WAY.' Applying Article 1544 of the Civil Code on double sales, the Court ruled in favor of Pante as the first possessor in good faith, having used the property as a passageway since 1963 and having acquired constructive delivery through the notarized contract. The decision affirmed that voidable contracts remain binding unless properly annulled by court action, and established important principles regarding possession in double sale situations.

Statutes applied

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By Intellegal Editorial Board · April 11, 2012

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