Luz S. Nicolas v. Leonora C. Mariano

Summary

This case involves a property dispute between Luz Nicolas and Leonora Mariano over mortgage and sale transactions concerning an NHA-granted lot in Caloocan City. Mariano, who had not fully paid her NHA installments, mortgaged the property twice to Nicolas and later executed a deed of absolute sale. All three court levels invalidated the transactions, with the Supreme Court affirming that Mariano, not being the true owner due to unpaid NHA obligations, could not validly transfer property rights under the principle nemo dat quod non habet. The Court applied the pari delicto doctrine, finding both parties equally at fault for knowingly entering invalid transactions, and denied relief to either party. The decision emphasizes the distinction between holding a certificate of title and actual ownership, particularly in installment sale arrangements with government agencies.