Isabelita S. Tangeli v. Luis P. Lorenzo, Jr.

Summary

This property dispute involved competing claims between registered heirs and successors-in-interest of an alleged purchaser in an accion publiciana. The Valenzuela heirs obtained a Torrens title through extrajudicial settlement after Gaspar's death, claiming a 1973 sale to Alfredo Duque was fraudulent. Lead Export, as successor of Duque, defended based on the validity of the notarized but unregistered deed of sale. The Supreme Court affirmed the Court of Appeals' ruling that the unregistered deed of sale was valid and binding between the parties and their heirs, applying the principle that registration is not required to bind the original parties and their heirs. The Court emphasized that as heirs of the original owner, petitioners were bound by their predecessor's acts, particularly since the widow Isabelita had co-signed the deed. The decision clarifies the provisional nature of ownership determinations in possessory actions and reinforces the binding effect of unregistered but valid contracts on the parties' heirs.