Felipa Binasoy Tamayao v. Felipa Lacambra

Summary

This Supreme Court case involves competing ownership claims over Lot No. 2930 between heirs of Juan Lacambra (respondents) and Spouses Tamayao (petitioners). The dispute arose from multiple sales of the same property: first, heirs of original owner Vicente Balubal sold to Juan Lacambra in 1962; second, some heirs of Lacambra sold 5/14 share to Spouses Tamayao in 1980; third, heirs of Balubal sold entire lot to Spouses Tamayao in 1981. The Supreme Court affirmed lower courts' decisions, upholding the validity of the 1962 sale based on the presumption of regularity of the notarized deed and actual possession by Juan's heirs. The Court invalidated the 1981 sale, finding Spouses Tamayao were not innocent purchasers for value as they had actual knowledge of the prior sale and adverse possession. The decision reinforces principles that registration does not confer ownership, sale is consensual in nature, and the doctrine 'nemo dat quod non habet' - one cannot give what one does not have.