Spouses Clemencio C. Sabitsana, Jr. v. Juanito F. Muertegui

Summary

This case involves a double sale of unregistered land where lawyer Atty. Sabitsana purchased property that his clients, the Muertegui family, had already bought ten years earlier. Garcia first sold the 7,500-square meter lot to Juanito Muertegui in 1981 via unnotarized deed, then sold the same lot to Atty. Sabitsana in 1991 via notarized deed. Despite knowing of the prior sale through his professional relationship with the Muertegui family, Atty. Sabitsana proceeded with the purchase and registered it first. The Supreme Court affirmed lower courts' decisions favoring Muertegui, clarifying that Act No. 3344, not Article 1544 of the Civil Code, governs unregistered land sales. The Court emphasized that the first buyer has better right regardless of registration, and condemned Atty. Sabitsana's breach of professional ethics in using confidential client information for personal gain, violating his duty of undivided loyalty to his clients.