G.R. No. L-5396
CANUTO REYES, petitioner-appellee, vs. JACINTO LIMJAP, opponent-appellant.
March 12, 1910

FACTS:

On January 3, 1906, Ireneo Felix applied for the registration of a parcel of land in Antipolo, Rizal, with an area of 815.98 square meters. He alleged acquiring the property by purchase from Vicente Francisco Ayco and that it was free from encumbrances. Before judgment, Felix sold the land to Canuto Reyes, the petitioner-appellee. Evidence showed that the land’s original owner, Crisostomo Marero, sold it under pacto de retro to Vicente Francisco Ayco on May 25, 1874. Marero failed to redeem it, and Vicente Francisco subsequently sold it to Irineo Felix on December 7, 1906, who then sold it to Canuto Reyes.

On April 4, 1907, Jacinto Limjap, the opponent-appellant, opposed the application, claiming to be the owner and present possessor, denying that Felix or his predecessors had legal possession. Limjap’s claim was based on a sale from Braulia Cuepangco.

During trial, it was proven that Crisostomo Marero was the original owner. Crucially, Braulia Cuepangco, Limjap’s vendor, never possessed nor claimed ownership of the disputed intermediate lot. Her son-in-law and attorney-in-fact, Dalmacio Guidote, testified that Cuepangco owned two adjacent lots but not the intermediate lot belonging to Marero (which was later acquired by Francisco and then Felix). Guidote explicitly stated he did not include this intermediate lot in the sale to Limjap, and initially refused to sign Limjap’s deed because it included a larger area. He only signed after being assured that the absence of an eviction and warranty clause would prevent serious issues.

The trial court overruled Limjap’s opposition and decreed the registration of the property in favor of Canuto Reyes. Limjap’s motion for a new trial was denied, leading to this appeal.

ISSUE:

Who has the better right to the land, and thus, who is entitled to its registration: Canuto Reyes, whose title is traced from Crisostomo Marero through Vicente Francisco Ayco and Irineo Felix, or Jacinto Limjap, whose title is traced from Braulia Cuepangco, a party who never owned or possessed the disputed land?

RULING:

The Supreme Court affirmed the decision of the trial court, upholding the adjudication and registration of the property in favor of Canuto Reyes.

The Court held that:
1. Valid Chain of Title for Reyes: The evidence clearly established Canuto Reyes’s legitimate chain of title originating from Crisostomo Marero, who validly sold the land pacto de retro to Vicente Francisco Ayco. Upon non-redemption, Ayco became the absolute owner, and his subsequent sales to Irineo Felix and then to Canuto Reyes were valid and transferred ownership. Vicente Francisco acquired just title and good faith possession, which he transmitted to his successors.
2. Lack of Title for Limjap’s Vendor: Braulia Cuepangco, Limjap’s alleged vendor, was never in material or civil possession of the land in question and had no intention of possessing it. Her own representative, Dalmacio Guidote, admitted that the disputed land belonged to a third party (Marero/Francisco/Felix) and was not included in the sale of Cuepangco’s adjacent lots to Limjap.
3. Principle of Nemo Dat Quod Non Habet: A vendor cannot transfer ownership of a property she does not own. Therefore, Cuepangco could not have conveyed any right over the disputed land to Limjap.
4. Contract Interpretation: The Court cited Articles 1281 and 1283 of the Civil Code, emphasizing that the evident intention of the contracting parties prevails over the words of a contract if they appear contrary, and that general terms in a contract should not include things not intended by the parties. Since the land in question was not owned by Cuepangco and was not intended to be part of the sale to Limjap, it could not be considered included in their instrument of sale, regardless of its terms.
5. Unquestionable Right to Registration: Reyes, having an unquestionable right based on a valid and efficient contract of sale (from Marero to Francisco) and subsequent transfers, is entitled to have his title recorded. Limjap failed to present a better title or prove any defect in Reyes’s claim.