Elisa Insures Salvaña v. Zosimo · G.R. 210624

Petitioner: Elisa Insures Salvaña
Respondent: Zosimo Labnao
Citation: G.R. No. 210624
Court: Supreme Court
Division: Third Division
Decided: December 10, 2018

Summary

This case involves a property dispute over Lot No. 15226-C inherited by the Insures family from Nieves Mabini. The petitioners alleged that Javilla Labnao fraudulently induced them to sign an extrajudicial settlement transferring their property to Manuel Cantos Development Corporation (MCDC), which later sold to Zosimo Labnao. The case presented a double sale scenario - an earlier 1987 sale to Sibonghanoy and the contested 1995 sale to MCDC. All three court levels ruled against petitioners, finding insufficient evidence of fraud and applying Civil Code Article 1544 to favor MCDC's registered ownership over Sibonghanoy's unregistered claim. The Supreme Court emphasized that fraud must be proven by clear and convincing evidence and affirmed the validity of the notarized settlement documents.

Statutes applied

Civil Code, Art. 1544

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By Intellegal Editorial Board · December 10, 2018

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