Peblia Alfaro v. Spouses Editho

Summary

This case involves a double sale dispute over Lot No. 1710 in Talisay City. Original owner Bagano first sold a portion to respondent Spouses Dumalagan in 1993, who took possession and made improvements. Bagano later sold the entire lot to petitioner Spouses Alfaro in 1995, who registered the title first. The Supreme Court affirmed the Court of Appeals' decision favoring respondents, ruling that petitioners were not purchasers in good faith. Key findings included: (1) res judicata from a prior case did not apply due to different parties and causes of action; (2) adverse claims remain effective until cancelled even after 30 days; (3) petitioners had actual knowledge of prior occupants and sales, defeating their good faith claim. The Court emphasized that under Civil Code Article 1544, the double sale rule requires good faith from all purchasers, and buyers cannot close their eyes to obvious defects in the seller's title.