Rufo Arcenas v. Inocencio del Rosario

Summary

This case involves a property dispute over Lot No. 3971 of the Capiz cadastre arising from competing sales. Inocencio del Rosario initially sold the property to Rufo Arcenas with right of repurchase in 1923, but when the repurchase period expired, he later sold the same property absolutely to the Cordova spouses in 1934. The spouses registered their deed and obtained title. The Supreme Court reversed the lower court's dismissal, holding that registration under Article 1473 of the Civil Code requires good faith and valuable consideration. Since the spouses knew of the prior sale and failed to fulfill their undertaking to repurchase from Arcenas, they were not purchasers in good faith. The case established important precedent regarding the good faith requirement in property registration and the independence of cross-complaints from principal actions.