Isabelo Cabalhin v. Spouses Bonifacio Lansuela

Summary

This property dispute involved a 34,661 sq. meter agricultural land registered under OCT No. P-2133 in the name of deceased Isidoro Cabalhin. His son Isabelo claimed ownership by inheritance and possession, while respondent spouses claimed ownership through an unregistered chain of sales from 1968 to 1988. The Supreme Court ruled that ownership was not validly transferred to respondents because there was no actual or constructive delivery of the property. The vendor Manaay could not transfer what he did not possess, and the execution of sale documents alone, without delivery, was insufficient to transfer ownership under Civil Code provisions. The Court emphasized that delivery is essential for ownership transfer and that respondents should have investigated why the petitioner remained in possession despite alleged prior sales. The decision reinforced the fundamental Civil Code principle that ownership passes only through proper delivery, not mere execution of sale documents.