Amos A. Davis v. Francisca Neyra

Summary

This case involved competing ownership claims over a house arising from a chain of sales. Julian Palma initially sold the property to plaintiff Davis through a pacto de retro sale for P1,000, then subsequently sold the same property through multiple transactions that eventually reached defendant Neyra. The Supreme Court had to determine whether the original Palma-Davis transaction was a sale with right to repurchase (pacto de retro) or antichresis, and which party had superior title. The Court ruled that the transaction was clearly a pacto de retro sale, meaning ownership passed to Davis with Palma retaining only the right to repurchase. Since neither party registered their title and the property was real, Article 1473 of the Civil Code governed. The Court found that Davis had first taken possession through Palma's tenancy arrangement, giving him superior title over Neyra despite her good faith purchase. This case establishes important precedent regarding the effects of pacto de retro sales on subsequent purchasers and the application of Article 1473 in double sale situations involving unregistered real property.