Case Digest on Double Sale cases (by Marvin Magaipo)

Pagaduan vs Estanislao
Facts: On Nov. 1961, Eugenia Reyes, executed a Unilateral Deed of Sale of Land,
selling the Northern portion to the respondents and the southern portion to Agaton,
father of the petitioners. A year later, Reyes executed an Absolute Deed of Sale,
conveying to the respondents the whole Land, and thus, respondents registered it in
ROD and a new TCT was issued.
Petitioners filed a complaint.
SC Ruling: This is a double Sale. The requirement, who first made the registration is
qualified with good faith. Registration in bad faith, is no registration at all. The fact
that the respondents knew that the southern portion was sold to Agaton, their
action in registration of the said land made them in bad faith.

BEatingo vs Gasis
Facts: Flora Gasis sold piece of land to the petitioner on May 19, 1998, it was
notarized. On Jan 1999, the same land was sold to the respondents Lilia. Petitioner
tried to registere the sale but it was oppsed by the respondent.
A case in RTC for annulment of Sale, REConveyance and delivery of Title. RTC ruled
that, that the respondents has better right against the petioner for the reason of
actual possession.
CA dismissed the Appeal.
SC affirmed the RTCs ruling. Art 1544: double Sale. When there is no inscription,
Actual possession will be considered.
FR. Martinez vs Veneracion
Facts: De la PAzes entered into an Oral contract of Sale, on Feb 1981 with Fr.
Martinez, worth 15K on installment with 3K as downpayment. Fr. Martinez
constructed a house on the said lot, with building permit, with the written consent
or approval by De la Paz, upon paying the downpayment.
On 1983, fully paid. Fr. Asked for the Absolute Deed of Sale, but nothing happened,
only promises by the dela Paz to do so.
On October 1981, Absolute of Deed of Sale with Right to Repurchase were entered
between Dela pZes and Veneracion, threeparcel of land including the lad bought by
Padre, amount 150K. Year later, it was modified to Absolute Deed of Sale, 180K and
it was registered with the ROD.

Petitioner knew the second sale, upon receiving a demand letter from Veneracion
demanding him to vacate the land.
MTC: Veneracion filed and ejectment case against Padre. MTC ruled, that Padre is
the owner, thus he was not ejected.
RTC: Veneracion made an appeal. RTC ruled that Veneracion is the owner and Padre
as builder in good Faith.
SC: Ruled that Veneracion is purchase and registrant in BAD Faith. Padre as real
owner of the land. This is based on the fact that Venracion in contacting the Sale
with delaPaz, knew already the existence of Padres house on the said lot. He must
inquired, why Padre is there before purchasing the said land.

Sps. Cruz vs Sps Fernando

Facts: Luis and Aida, occupant if front portion of the 710sgm land of Glorioso.
Glorioso and Cruzes have KASUNDUAN, a contract to Sell, offering to Cruzes to
purchase the back portion and to transfer their house to the said back portion
aupon fulfillment of the Sale. But this Kasunduan never realized for the failure of
Cruz to pay.
Cruzes, lived and built their house on the said land by tolerance of the previous
owner who were their relatives.
Respondents, Fernandos filed and accion publiciana with the RTC, against the
Cruzes, demanding them to vacate and pay rental of 500/mos, alleging that they
are the real owner of the whole land as they bought it for Glorioso on March 1987,
evidence with Deed of Sale.
RTC: is in favor to the Fernandos.
CA: Affirmed the RTCs ruling
SC: Fernandos are not buyer in BAD Faith, for there were no valid Contract of Sale
which arises for the KASUNDUAN between Glorioso and Cruzes. NO double sale to
apply.