- Petitioner
- Spouses Juan
- Respondent
- Spouses Arturo
- Citation
- G.R. No. 188666
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Sereno, J.
- Decided
- December 14, 2017
Summary
This consolidated case involves a family property dispute over land in Pangasinan between relatives claiming competing titles. Petitioners Juan and Antonina Cano claimed ownership via an unregistered donation propter nuptias from 1962, while respondents Arturo and Emerenciana Cano claimed ownership via a registered deed of absolute sale from 1982. The Supreme Court ruled in favor of respondents, holding that while the donation propter nuptias was valid under Civil Code provisions, unregistered rights do not bind third persons under Article 709 and PD 1529. Respondents were declared innocent purchasers for value who could rely on the registered title. The Court clarified that donations propter nuptias under the Civil Code do not require express acceptance, correcting the Court of Appeals' reasoning, but affirmed the ultimate conclusion that registered rights prevail over unregistered ones as to third parties.