Aleida Saavedra v. Rafael Martinez

Summary

This case involves the fraudulent sale of conjugal partnership property by husband Ceferino Ibañez to Rafael Martinez while a support judgment in favor of his wife and minor children remained unsatisfied. Despite a lis pendens annotation on the property title, the register of deeds cancelled it, enabling the sale. The Supreme Court applied Article 1297 of the Civil Code's presumption of fraudulent alienation, finding Martinez had constructive notice of the unsatisfied judgment and failed to verify its satisfaction. The Court rescinded the sale to Martinez but protected third-party mortgagee W.S. Price who acted in good faith. The decision demonstrates the balance between protecting family property rights and safeguarding innocent purchasers, while establishing the duty of buyers to verify claims against properties they intend to purchase.