Petitioner
Francisco
Respondent
Hon. Court of Appeals (Twelfth Division)
Citation
G.R. No. 84051
Court
Supreme Court
Division
First Division
Ponente
Cruz, J.
Decided
May 19, 1989

Summary

The Supreme Court denied petitioners' claim to a 5,900 square meter property in Pangasinan in this double sale dispute. Marciana Trinidad sold the same inherited land twice - first to petitioners' parents in 1928 via Escritura de Compraventa, then to a Parent-Teacher Association in 1947 who later donated it to the Republic in 1977. The Court ruled petitioners were barred by prescription and laches, having waited 34 years (until 1981) to challenge the Republic's possession despite obvious improvements and enclosures since 1947. The belated registration of their deed in 1964 was made in bad faith. Under Civil Code Article 1544 governing double sales, the Republic prevailed as the party first in possession in good faith. The decision reinforces the principles that stale claims will not be entertained and that good faith possession takes precedence in property disputes involving double sales.

Statutes applied

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By the Intellegal Editorial Board · May 19, 1989

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