Angel M. Pagaduan v. Spouses Estanislao & Fe Posadas Ocuma

Summary

This property dispute involved competing claims over an 8,754-square-meter land portion. Agaton Pagaduan purchased the southern portion from Eugenia Reyes on November 26, 1961, while the spouses Ocuma purchased the northern portion on the same date and in the same deed. Subsequently, Eugenia sold the entire property including the southern portion to the Ocumas on June 5, 1962, who then registered it. The Pagaduan heirs filed for reconveyance in 1989. The Supreme Court ruled this was a double sale case under Article 1544 of the Civil Code, not an implied trust. Since the Ocumas had actual knowledge of the prior sale to Pagaduan (both sales were in the same deed), their subsequent registration was in bad faith and ineffectual. The Court reversed the Court of Appeals' prescription ruling and reinstated the trial court's decision ordering reconveyance to the rightful owners.