Petitioner
Lorenzo Berico
Respondent
The Honorable Court of Appeals (Former Ninth Division)
Citation
G.R. No. 96306
Court
Supreme Court
Division
Third Division
Ponente
Davide, Jr., J.
Decided
August 20, 1993

Summary

This landmark case involves a double sale of immovable property where Jose de los Santos sold 2.25 hectares to private respondents in 1961, then sold the entire lot including the same portion to petitioners in 1963. Despite petitioners having prior knowledge of the first sale and recognizing private respondents' possession, they registered their deed in 1968 and secured a title. Private respondents filed for annulment of title in 1978. The Supreme Court ruled that registration in bad faith under Article 1544 of the Civil Code is ineffectual and confers no preferential rights. The Court emphasized that good faith is the fundamental premise of Article 1544's protections, and since private respondents were the first possessors in good faith, they should prevail. The decision clarifies that the Torrens system cannot be used to perpetrate fraud and that actions to quiet title do not prescribe.

Statutes applied

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By the Intellegal Editorial Board · August 20, 1993

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