Agricultural v. Court of Appeals

Summary

This case involves a property ownership dispute between two successive purchasers of the same 19-hectare land in Las Piñas, Rizal. In 1972, the Diaz spouses first sold the property to Bruno Gundran, who formed a joint venture with petitioner Agricultural and Home Extension Development Group. However, Gundran failed to register the sale due to existing lis pendens notices. In 1976, the same spouses sold the identical property to respondent Librado Cabautan, who immediately registered the sale and obtained a new certificate of title. The Supreme Court applied Article 1544 of the Civil Code, which provides that in cases of double sale of immovable property, ownership belongs to the person who in good faith first records the sale. Finding that Cabautan was a purchaser in good faith who promptly registered his acquisition while Gundran failed to register despite having four years to do so, the Court upheld Cabautan's superior right to the property. The decision reinforces the fundamental principle that registration is the operative act to convey land under the Torrens system and protects innocent purchasers for value who rely on the certificate of title.