Skunac Corporation v. Roberto S. Sylianteng

Summary

The Supreme Court affirmed the Court of Appeals decision in favor of respondents Roberto and Caesar Sylianteng in a property ownership dispute over two lots in Greenhills, San Juan City. The case involved competing claims: respondents traced their ownership through a 1958 sale from original owner Luis Pujalte to their mother Emerenciana Sylianteng, while petitioners Skunac Corporation and Alfonso Enriquez claimed ownership through Romeo Pujalte, who alleged he was Luis's sole heir. The Court found that Romeo Pujalte was not a legitimate heir and had used falsified documents to deceive the estate court, as proven in a separate criminal case. Since the disputed lots were already sold by Luis during his lifetime, they never formed part of his estate. Applying the principle 'nemo dat quod non habet,' the Court ruled that Romeo could not transfer rights he never possessed. The Court also found petitioners acted in bad faith, having notice of prior transactions through title annotations. The decision validates the importance of careful title verification and the consequences of dealing with parties lacking legitimate ownership rights in real property transactions.