Afp Retirement v. Plastic King Industrial Corp.

Summary

The Supreme Court resolved a double sale dispute involving Lot Y-2-C in General Santos City. Atty. Flaviano first sold the property to Plastic King Industrial Corp. in 1995, then sold the same property to AFP-RSBS in 1997. The Court held that the first sale to Plastic King was valid and could not be revoked by an unauthorized agent. AFP-RSBS was not an innocent purchaser for value because it had actual notice of the prior sale and pending litigation through lis pendens annotations before completing its registration. The Court applied the Duenas doctrine requiring good faith to exist until registration. The titles issued to AFP-RSBS were declared void, and the Court ordered direct issuance of new titles to Plastic King as the rightful owner. This case reinforces the principle that buyers with notice of prior adverse claims cannot invoke protection as innocent purchasers, and that good faith must be maintained throughout the entire acquisition process including registration.