Abuyo v. Suazo
REITERATIONFacts
The Antecedents: Plaintiffs, heirs of the original owner Ambrosio Abuyo, sought to recover a 3-hectare portion of a nearly 10-hectare land. Their father had sold this 3-hectare portion to Gregorio Suazo, husband of the defendant Concepcion B. de Suazo, via a deed of sale dated May 8, 1939. The vendee and his wife took possession, fenced the property, and paid taxes thereon. The original owner died on May 28, 1946. Procedural History: The plaintiffs filed a suit to recover ownership and possession of the disputed 3-hectare portion. The court below rendered a judgment in favor of the defendant. The Appeal: The plaintiffs appealed the decision of the Court of First Instance directly to the Supreme Court. They questioned the lower court's finding that the deed of sale was genuine and urged a review of the evidence. Their appeal was filed via a Record on Appeal, praying for the elevation of the case to the Supreme Court.
Issue(s)
Whether the plaintiffs, as heirs of the vendor, are bound by an unrecorded deed of sale executed by their predecessor-in-interest. Whether the Supreme Court can review the findings of fact of the trial court in a direct appeal.
Ruling
The Supreme Court affirmed the judgment of the lower court. The plaintiffs are bound by the deed of sale executed by their father and cannot recover ownership and possession of the disputed portion of land from the defendant.
Ratio Decidendi
On the issue of reviewing findings of fact in a direct appeal: The Court held that when an appeal is taken directly to the Supreme Court from the Court of First Instance, the appellant is bound by the findings of fact of the trial court. Such an appeal limits the appellant to raising only questions of law. By choosing a direct appeal, the plaintiffs are deemed to have accepted the facts as found by the lower court, making those findings final and not subject to review. Therefore, the Court could not re-examine the genuineness of the deed of sale. On the binding effect of an unrecorded deed of sale on heirs: The Court reiterated the principle that an unrecorded deed of sale, while not taking effect as a conveyance to bind the land against third persons without notice, operates as a contract between the parties. This contract is also binding upon the vendor's privies, which include the vendor's heirs. The purpose of registration is to give notice to third persons, and since the heirs are not third persons, the failure to register the deed of sale does not vitiate the vendee's right of ownership conferred by the unregistered deed. Actual notice is equivalent to registration in binding the parties and their privies. Consequently, the plaintiffs, as heirs of Ambrosio Abuyo, are bound by the deed of sale executed by their father in favor of Gregorio Suazo.
Main Doctrine
The Supreme Court affirmed that an unrecorded deed of sale, though not effective as a conveyance to bind the land against third persons without notice, remains valid and binding between the parties thereto and their privies. This is because actual notice is considered equivalent to registration for the purpose of binding those in privity with the original parties, such as heirs. The primary function of registration under the Land Registration Act is to provide notice to third parties, not to validate the contract between the vendor and vendee.