- Petitioner
- Domiciano Gonzaga
- Respondent
- Angel Javellana
- Citation
- G.R. No. 6843
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Arellano, C.J.
- Decided
- September 3, 1912
Summary
This landmark 1912 Supreme Court case established the priority rule under Civil Code Article 1473 for resolving competing claims to real property. When Jose Lim sold the same parcel of land to two different purchasers - first to Gonzaga in 1905, then to Javellana in 1908 - the Court held that ownership belongs to whoever first recorded the sale in the property registry. Despite Javellana having actual possession, Gonzaga's prior registration (December 15, 1909 vs. May 5, 1910) gave him priority. The decision rejected claims that the first sale was simulated, finding sufficient evidence of valuable consideration and genuine transaction. This case remains foundational for Philippine property law regarding double sales and registration priorities.