Sapto v. Fabiana
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a four-hectare parcel of land in Davao City, originally registered under Transfer Certificate of Title No. T-5701 (0-28) in the name of the deceased Moro Sapto. Sapto's heirs, Samuel and Constancio Sapto, sold a portion of this land to defendant Apolonio Fabiana on June 6, 1931, for P245.00. Although the sale was approved by the Provincial Governor, it was never registered. Possession of the land was transferred to Fabiana, who has occupied it continuously since 1931. 2. Procedural History: Following the deaths of Constancio Sapto (without issue) and Samuel Sapto (survived by his widow Dora and children Laureana and Vicente Sapto), the widow and children of Samuel Sapto filed an action in the Court of First Instance of Davao on October 19, 1954, seeking to recover the land sold in 1931. The lower court ruled that the unregistered sale was valid and binding between the parties and their heirs, ordering the plaintiffs to execute a deed of conveyance. The plaintiffs appealed this decision to the Supreme Court. 3. The Petition: The appellants (plaintiffs) are appealing the lower court's decision, questioning whether an unregistered deed of sale, despite the transfer of possession, is valid and binding on the heirs of the vendors. They argue that the appellee's action to obtain a deed of conveyance had prescribed, as twenty years had elapsed since the original sale. The appellants also cite cases where registration is considered the operative act for title transfer under the Torrens system. The appellee, conversely, contends that as he has remained in continuous possession and no innocent third parties are involved, the sale is valid between the parties and their heirs, and the action to quiet title is imprescriptible while in possession.
Issue(s)
Whether the unregistered deed of sale executed by appellants' predecessors in favor of the appellee over the land in question is valid and binding on appellants and operated to convey title and ownership to the appellee. Whether the action to require the appellants to execute a deed of conveyance had prescribed.
Ruling
The judgment of the lower court is affirmed. The unregistered deed of sale is valid and binding between the parties and their heirs. The action to quiet title is imprescriptible as the plaintiff-appellee remained in possession of the land.
Ratio Decidendi
On the validity and binding effect of the unregistered deed of sale: The Court reiterated its consistent interpretation of Section 50 of the Land Registration Act, holding that as between the parties to a sale, registration is not necessary to make it valid and effective. Actual notice is equivalent to registration. The Court cited numerous cases, including Obras Pias vs. Devera Ignacio, Gustilo vs. Maravilla, and Galanza vs. Nuesa, to support the principle that registration is primarily intended to protect buyers against claims of third persons arising from subsequent alienations by the vendor. In this case, no rights of innocent third persons or subsequent transferees are involved, and the property has remained in the possession of the vendee. Therefore, the conveyance is valid and binding upon the vendors and their heirs. To hold otherwise would allow the Torrens system to be used as a shield for fraud. On the prescription of the action to execute a deed of conveyance: The Court overruled the contention that the action had prescribed. It clarified that the action was not merely for the performance of the contract of sale but was essentially an action to quiet title, which accrued when the appellants initiated their suit to recover the land in 1954. Furthermore, the Court invoked the established rule of American jurisprudence, made applicable in the Philippines, that actions to quiet title to property in the possession of the plaintiff are imprescriptible. The prevailing rule is that the right to quiet title is not barred while the owner remains in actual possession, as they have a continuing right to seek aid from the court to determine the nature of adverse claims against their title.
Main Doctrine
As between vendor and vendee, registration of a deed of sale is not necessary to make it valid and effective, as actual notice is equivalent to registration. An action to quiet title to property in the possession of the plaintiff is imprescriptible.