G.R. No. L-73651 November 27, 1987
IGNACIO CARDENTE and ANASTACIA T. CARDENTE, petitioners, vs. THE INTERMEDIATE APPELLATE COURT and SPOUSES RUPERTO RUBIN and PRIMITIVA C. RUBIN, respondents.

FACTS

This case involves a double sale of an immovable property. In 1956, Francisca Cardente, on behalf of her minor grandson petitioner Ignacio Cardente, purchased a one-hectare portion of a larger parcel from Isidro Palanay. The sale was evidenced by a private document, which was later lost. The Cardentes immediately took possession, cultivated the land, and remained in continuous, adverse possession. In 1960, Palanay sold the entire property, including the one-hectare portion, to respondent spouses Ruperto and Primitiva Rubin. The Rubins registered their deed of sale and obtained a new Transfer Certificate of Title. In 1972, Palanay executed a public document confirming the 1956 sale to Cardente, which explicitly stated that Rubin had been informed of the prior sale.
In 1977, the Rubins filed a complaint to quiet title. The trial court dismissed their complaint and ordered them to reconvey the one-hectare portion to Cardente. The Intermediate Appellate Court reversed, declaring the Rubins as absolute owners and ordering the Cardentes to vacate, prompting this petition.

ISSUE

Whether the second vendees (Rubin spouses) are entitled to ownership under Article 1544 of the Civil Code, despite their prior registration of the sale, given the finding of their bad faith.

RULING

The Supreme Court reversed the appellate court and reinstated the trial court’s decision. The resolution of this double sale is governed by Article 1544 of the Civil Code, which provides that ownership of immovable property shall belong to the person who in good faith first recorded it in the Registry of Property. Registration alone is insufficient; it must be coupled with good faith. Bad faith vitiates the registration.
The Court found that the Rubins were not purchasers in good faith. The 1972 Deed of Confirmation executed by the original vendor, Palanay, explicitly stated that Rubin was informed of the prior sale to Cardente. This was corroborated by testimony. Furthermore, the Rubins’ conduct—specifically, their failure to assert their alleged ownership for seventeen years despite the Cardentes’ open, continuous, and adverse possession—belied their claim of good faith. A purchaser of registered land is charged with the duty to see the occupants and inquire into their rights; failure to do so negates good faith. The Rubins’ prolonged inaction constituted an acceptance of the prior sale. Consequently, their registration, tainted by bad faith, conferred no superior right. Ownership rightfully pertains to the first vendees, the Cardentes, who were first in possession and had a just title.