G.R. No. 145878 ; April 25, 2006
MARCIANO BLANCO, Petitioner, vs. FELIMON RIVERA, Respondent.

FACTS

The controversy involves a 217-square-meter residential lot formerly co-owned in equal shares by respondent Felimon Rivera and his mother, Eugenia Reyes. On February 21, 1977, Eugenia sold her undivided share to her other son, petitioner Marciano Blanco. This sale was not registered because the original title was allegedly in respondent’s custody. Three years later, on April 19, 1980, Eugenia sold the same undivided share to respondent Felimon Rivera via a quitclaim deed. Respondent successfully registered this second sale and obtained a new title. He subsequently took possession and paid real property taxes.
Petitioner, who resided on a portion of the property, learned of the second sale in 1982. He confronted his mother, leading to barangay proceedings where he presented his 1977 deed of sale. Respondent denied knowledge of the prior sale and later filed an ejectment case against petitioner, which was decided in petitioner’s favor. In 1991, respondent filed a civil case for quieting of title. The trial court ruled in favor of respondent, a decision affirmed by the Court of Appeals.

ISSUE

Who, between petitioner (the first buyer) and respondent (the second buyer), has a better right to the subject property?

RULING

The Supreme Court denied the petition and affirmed the lower courts’ rulings, upholding respondent Felimon Rivera’s ownership. The Court applied Article 1544 of the Civil Code, which governs double sales of immovable property. The law provides that ownership shall pertain to the person who in good faith first recorded the acquisition in the Registry of Property.
The Court emphasized that the requirement is two-fold: acquisition in good faith and registration in good faith. For the second buyer to gain priority over the first, he must register the sale in good faith, meaning without knowledge of the prior alienation. In this case, the Court found that respondent was a purchaser and registrant in good faith. There was no conclusive evidence presented that he had knowledge of the 1977 sale to petitioner at the time of his purchase and registration in 1980. Petitioner failed to prove that respondent acted in bad faith. Furthermore, petitioner’s inaction for years—failing to take legal steps to annotate his claim or assert his right despite knowing the original title was with respondent—prejudiced his claim. Consequently, respondent, as the first registrant in good faith, acquired a superior right.