Gregoria R. de Mesa v. Cipriano V. de Galicia

Summary

This case involves a dispute over the right of legal redemption of property sold in execution sale. Gregoria R. de Mesa first purchased the redemption right from property owner Andres Imperial in December 1936, with Cipriano V. de Galicia signing as witness. Subsequently, Galicia purchased the same right from Imperial in January 1937 and immediately exercised it. The trial court favored Galicia based on the first-to-register rule under Article 1473 of the Civil Code. However, the Supreme Court reversed, emphasizing that registration must be in good faith. Since Galicia knew of Mesa's prior purchase (having witnessed it), his registration was in bad faith. The Court ruled that Galicia only acquired Imperial's conditional right to redeem from Mesa, which expired on March 26, 1937. The decision establishes the principle that good faith is essential for effective registration and that a purchaser with knowledge of prior sales acquires only the vendor's remaining rights.