G.R. No. 160132 ; April 17, 2009
SERAFIN, RAUL, NENITA, NAZARETO, NEOLANDA, all surnamed NARANJA, AMELIA NARANJA-RUBINOS, NILDA NARANJA-LIMANA, and NAIDA NARANJA-GICANO, Petitioners, vs. COURT OF APPEALS, LUCILIA P. BELARDO, represented by her Attorney-in-Fact, REBECCA CORDERO, and THE LOCAL REGISTER OF DEEDS, BACOLOD CITY, Respondents.

FACTS

Roque Naranja, single and without children, was the registered owner of Lot No. 4 (TCT No. T-18764) and a co-owner of a one-third share in adjacent Lot No. 2 (TCT No. T-18762) with his brothers and their heirs (the petitioners). The lots were leased, providing Roque a monthly income. In 1976, Roque lived with his half-sister, respondent Lucilia P. Belardo. On August 21, 1981, Roque executed a notarized Deed of Sale, selling Lot No. 4 and his one-third share in Lot No. 2 to Belardo for ₱10,000.00, citing “other valuable consideration” and gratitude for her support. The titles were given to Notary Public Atty. Eugenio Sanicas for registration, but registration was delayed as Belardo lacked funds for fees. Later, to secure a ₱15,000.00 loan from Margarita Dema-ala for Roque’s expenses, Roque executed another deed of sale for the same properties on November 19, 1983, for ₱30,000.00, with Belardo as a witness. Roque died on December 2, 1983. Belardo fully paid the loan in 1985, and Dema-ala returned the titles. Unbeknownst to Belardo, the petitioners (heirs of Roque’s brothers) executed an Extrajudicial Settlement Among Heirs on October 11, 1985, adjudicating Lot No. 4 to themselves. Using Roque’s copy of TCT No. T-18764 obtained from Atty. Sanicas, they secured a new title (TCT No. T-140184) in their names. Belardo, upon discovering this, registered the 1981 Deed of Sale only on TCT No. T-18762, as TCT No. T-18764 was already cancelled. Belardo (through her attorney-in-fact) filed a suit for reconveyance (Civil Case No. 7144). Petitioners filed a separate case for annulment of sale and quieting of title (Civil Case No. 7214). The Regional Trial Court (RTC) ruled in favor of petitioners, declaring the 1981 Deed of Sale null and void due to alleged defects in form and lack of registration. The Court of Appeals (CA) reversed the RTC, upholding the validity of the 1981 Deed of Sale, declaring the Extrajudicial Settlement void, and recognizing Belardo as the owner. Petitioners elevated the case to the Supreme Court.

ISSUE

1. Whether the Deed of Sale dated August 21, 1981, is valid and effective in transferring ownership to Belardo despite alleged formal defects and non-registration.
2. Whether the petitioners, as heirs of Roque Naranja, have a superior right to the properties over Belardo, the vendee.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals Decision.
1. The 1981 Deed of Sale is valid and effective. The contract of sale was a consummated contract. Ownership of the properties was transferred to Belardo upon the delivery of the deed, which constituted constructive delivery of the immovable property. The alleged defect in form—the absence of a technical description—does not invalidate the sale. The law does not require a technical description for the validity of a contract of sale; the description referring to the lot numbers and corresponding TCTs sufficiently identified the properties. The lack of immediate registration does not affect the validity of the transaction between the parties; registration is only for the purpose of binding third persons. The consideration was validly established as ₱10,000.00 and “other valuable consideration,” which included Belardo’s support and care for Roque. There was no evidence of vitiated consent, lesion, or inadequacy of price that would invalidate the sale.
2. Petitioners, as heirs, have no superior right. The properties were sold by Roque during his lifetime; thus, they no longer formed part of his estate upon his death. Petitioners, as heirs, merely stepped into the shoes of Roque and are bound by the contract he entered into. They are not purchasers or innocent third parties for whose protection the registration laws are designed. Therefore, their subsequent Extrajudicial Settlement over Lot No. 4, a property already sold, was void. The principle of “first in time, stronger in right” (Article 1544 of the Civil Code) on double sales is inapplicable as petitioners are not purchasers but heirs claiming through their predecessor. Belardo’s prior purchase prevails.