G.R. No. 1715
July 3, 1905

FACTS:
1. Pedro Sarmiento died intestate in 1875, owning and possessing the disputed land. He left six legitimate sons, including Nicomedes Sarmiento and five other brothers (predecessors of the plaintiffs).
2. In December 1876, Nicomedes Sarmiento filed a “summary possessory information” (información posesoria) in his own name, claiming possession of the land for thirty years, which was approved in 1877 “without prejudice to third parties.” This was inscribed in the Property Register on August 8, 1891.
3. On September 23, 1891, Nicomedes sold the land to his attorney, Antonio Roxas, via a deed stating he acquired it by inheritance from his father and had possessed it since his father’s death. The deed was recorded on September 26, 1891.
4. On September 25, 1891, Antonio Roxas obtained a title to the same land through composition with the State (adjustment of land titles under Spanish law). This title was recorded on September 26, 1891.
5. Antonio Roxas later sold the land to Mariano Caragdag on August 22, 1896, conveying both the deed from Nicomedes and the composition title. This sale was recorded.
6. On August 2, 1897, Mariano Caragdag sold the land to Rafaela Paguia (widow of Antonio Roxas), and the sale was recorded on October 5, 1897.
7. Evidence showed that a sister of Nicomedes had previously sued him for partition of the fishery among the six brothers. Antonio Roxas, as Nicomedes’s attorney, entered into an agreement for division, but never executed it. The heirs repeatedly demanded compliance from Antonio Roxas and later from Rafaela Paguia after Roxas’s death, to no avail.

ISSUE:
Whether Rafaela Paguia acquired valid ownership of the land despite the plaintiffs’ claim that Nicomedes Sarmiento’s original sale to Antonio Roxas was void, as Nicomedes only held a pro-indiviso share and could not convey the entire property.

RULING:
The Supreme Court affirmed the lower court’s decision, ruling in favor of Rafaela Paguia as the rightful owner.

The Court applied Article 34 of the Mortgage Law (Spanish Mortgage Law then in force), which protects third parties who rely on the Property Registry. Under Article 34, instruments executed by a person appearing in the Registry as having a right are not invalidated against third persons once recorded, even if the grantor’s right is later annulled due to prior unrecorded deeds or undisclosed reasons.

Here, Nicomedes Sarmiento’s possessory information was recorded in 1891, making him appear as the rightful owner in the Registry. Antonio Roxas and subsequent buyers (Mariano Caragdag and Rafaela Paguia) relied on this recorded title. Although Nicomedes’s sale may have been invalid as to the plaintiffs’ shares (since the land was actually co-owned by all six brothers), the recorded transactions protected Rafaela Paguia as an innocent third-party purchaser.

The Court emphasized that the plaintiffs’ prior unrecorded rights could not defeat the recorded titles acquired by Roxas and his successors. Thus, Rafaela Paguia’s ownership was upheld. Costs were assessed against the plaintiffs-appellants.

Arellano, C.J., Torres, Johnson, and Carson, JJ., concurred.