Spouses Juanito P. Miciano v. Riza Bulseco-Obana Represented By Her Attys.-In-Fact

Summary

This Supreme Court case involves competing claims over immovable property covered by TCT No. T-189399. Obana purchased the property from Spouses Bantilan in 2006 through private sale and took possession. Subsequently, Spouses Miciano acquired the same property in 2008 through public auction sale following judicial foreclosure against Spouses Bantilan. When RTC Branch 10 nullified the certificates of sale in favor of Obana, Spouses Miciano challenged this on grounds of judicial interference. The Supreme Court denied their petition, ruling that RTC Branch 10 properly exercised jurisdiction and that under Article 1544 of the Civil Code, Obana has superior right as the first possessor in good faith. The decision reinforces the principle that purchasers at auction sales acquire only the rights possessed by the judgment debtor, and that prior unregistered sales can prevail over subsequent auction purchases based on good faith possession.