Petitioner
Mr.
Respondent
Mr.
Citation
G.R. No. 222530
Court
Supreme Court
Division
Third Division
Ponente
Inting, J.
Decided
October 16, 2019

Summary

This case involves conflicting ownership claims over a 1,214 sq.m. property originally co-owned by the Orbetas. Petitioners bought 500 sq.m. from one co-owner (Manuel Orbeta) in 1983, while respondents purchased the entire property from all co-owners in 1986 and 1990, subsequently registering it under the Torrens system. The Supreme Court affirmed lower court rulings favoring respondents, holding that Article 1544 on double sales is inapplicable since different vendors sold to different buyers. The Court ruled that defective notarization of the deed of sale does not invalidate the transaction but merely reduces it to a private document provable by preponderance of evidence. Petitioners' challenge to respondents' title was deemed a prohibited collateral attack under the Property Registration Decree. The decision reinforces the indefeasibility of Torrens titles and the principle that property sales remain valid despite notarization defects when properly proven.

Statutes applied

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By Intellegal Editorial Board · October 16, 2019

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