Blanco v. Rivera
REITERATIONFacts
The Antecedents: Respondent Felimon Rivera filed a civil case for quieting of title over a parcel of residential land against his half-brother, petitioner Marciano Blanco. The land was co-owned by respondent and their mother, Eugenia Reyes vda. de Rivera. On February 21, 1977, Eugenia sold her undivided share to petitioner. The sale could not be registered as the original title was with respondent, who refused to surrender it. Eugenia executed an affidavit stating she had notified respondent of the sale. On April 19, 1980, Eugenia sold her share again, this time to respondent Felimon, through a quitclaim deed. Respondent registered this sale and was issued a new title (TCT No. 501585). He took possession and paid taxes. Petitioner learned of the sale in 1982 and confronted his mother. In barangay proceedings, petitioner presented the deed of sale and affidavit. He claimed he could not register his sale because he only had a photocopy of the title, the original being with respondent, who refused to surrender it. Procedural History: Respondent filed an ejectment case against petitioner, which was decided in favor of petitioner. Respondent then filed the present civil case for quieting of title. The RTC ruled in favor of respondent Felimon Rivera, declaring him the true and lawful owner. The Court of Appeals affirmed the RTC decision. Hence, this petition. The Petition: Petitioner contends that respondent did not act in good faith when he purchased and registered the sale, and that as the first buyer, he has a better right.
Issue(s)
Whether respondent Felimon Rivera acted in good faith in registering the sale of Eugenia's share of the property, and whether petitioner Marciano Blanco has a better right to Eugenia's share of the property as the first buyer.
Ruling
The petition is denied. The assailed decision and resolution of the Court of Appeals are affirmed. Felimon Rivera is declared the true and lawful owner of the property covered by Transfer Certificate of Title No. 501585.
Ratio Decidendi
On the issue of good faith and better right to the property: The Court affirmed the ruling of the Court of Appeals and the RTC, holding that respondent Felimon Rivera has the better right to Eugenia's share of the property. Article 1544 of the Civil Code governs the sale of immovable property to two different buyers at different times. Ownership pertains to the person who in good faith first recorded the sale in the Registry of Property. If there is no inscription, ownership pertains to the person who in good faith was first in possession. In the absence of possession, it pertains to the person who presents the oldest title, provided there is good faith. The requirement is two-fold: acquisition in good faith and registration in good faith. Mere registration is not enough; good faith must concur with registration. To have priority status, the second purchaser must be in good faith, meaning without knowledge of the previous alienation. In this case, both the trial and appellate courts declared respondent Felimon Rivera as the true owner. He was the first to register his ownership, and there was no proof of his knowledge of the prior sale to petitioner. Therefore, his acquisition and registration were in good faith. The Court gave no weight to petitioner's claim of prior purchase, noting the lack of proof of notice to the co-owner (respondent) beyond an affidavit, which was denied by respondent in open court. The Court also found that petitioner was guilty of laches, having failed to assert his claim for an unreasonable and unexplained length of time (over 14 years) from his alleged acquisition until the filing of the quieting of title case.
Main Doctrine
Registration of title to immovable property must be coupled with good faith to acquire priority. Good faith requires that the second buyer be without knowledge of the previous alienation of the property.