Salera v. Rodaje
REITERATIONFacts
The Antecedents: This case concerns a dispute over the ownership of a parcel of land. The petitioners, Spouses Avelino and Exaltacion Salera, claim ownership based on a Deed of Absolute Sale executed on June 23, 1986, by the heirs of Brigido Tonacao. They allege they acquired the property from Brigido's heirs and have been in possession since before the sale, even constructing a house on the land. The respondents, Spouses Celedonio and Policronia Rodaje, assert ownership through a Deed of Absolute Sale dated June 6, 1986, from Catalino Tonacao, Brigido's father. They claim to have acquired the property through a verbal contract prior to the deed, registered the sale, and have been in peaceful, public, and adverse possession, constructing a store on the property. Procedural History: The Spouses Salera filed a complaint for quieting of title against the Spouses Rodaje with the Regional Trial Court (RTC), Branch 11, Calubian, Leyte, docketed as Civil Case No. CN-27. The RTC ruled in favor of the petitioners, declaring them the rightful owners, nullifying the sale between Catalino Tonacao and the respondents, and ordering the cancellation of the respondents' tax declaration. The respondents appealed this decision to the Court of Appeals (CA). The CA reversed the RTC's decision, declaring the respondents the true and lawful owners, directing the cancellation of the petitioners' deed of sale, and reinstating the respondents' deed of sale and tax declaration. The petitioners then filed the present Petition for Review on Certiorari with the Supreme Court. The Petition: The petitioners seek review of the Court of Appeals' decision, arguing that the CA erred in applying Article 1544 of the Civil Code. They contend that Article 1544 applies only to double sales by a single vendor, whereas this case involves sales by two different individuals, Catalino and Brigido's heirs, with Catalino not being the owner. The petitioners maintain that Brigido was the true owner, and thus his heirs could validly sell the property to them. They also challenge the respondents' claim of good faith, pointing to evidence that the respondents knew the property was declared in Brigido's name and that the RTC found them to be purchasers in bad faith. The Supreme Court agreed to review the case, noting the conflict between the findings of fact of the RTC and the CA.
Issue(s)
Whether Article 1544 of the Civil Code on double sales applies to the present case. Whether respondents are buyers in good faith. Whether petitioners have a superior right to the property.
Ruling
The petition is GRANTED. The assailed Decision of the Court of Appeals is REVERSED and the Decision of the trial court is REINSTATED. Petitioners Spouses Avelino and Exaltacion Salera are declared the rightful and legal owners of the property.
Ratio Decidendi
On the applicability of Article 1544 of the Civil Code: The Supreme Court held that Article 1544 of the Civil Code, which governs double sales, contemplates a situation where the same immovable property is sold by a single vendor to different vendees. It does not apply when the property is sold by two different persons, especially when one of them is not the owner. In this case, the property was sold by Brigido Tonacao's heirs to the petitioners, and by Catalino Tonacao (Brigido's father) to the respondents. Therefore, the CA erred in applying Article 1544 to accord preferential rights to the respondents based on registration and possession. On whether respondents are buyers in good faith: The Court found that respondents were not buyers in good faith. Evidence showed that respondents knew the property was declared for taxation purposes in the name of Brigido Tonacao. Respondent Celedonio Rodaje admitted that Catalino Tonacao presented the Tax Declaration of his son, Brigido, when asked for proof of ownership. This knowledge, coupled with the fact that they purchased from Catalino, who was not the declared owner, indicated bad faith. The trial court, which had the opportunity to observe the parties, correctly concluded that respondents' claim of good faith was without merit. On whether petitioners have a superior right to the property: The Court reinstated the RTC's decision, which declared petitioners as the rightful owners. The RTC correctly found that Brigido Tonacao was the declared owner, and upon his death, the property passed by operation of law to his heirs. Catalino Tonacao, as the father of the deceased Brigido, was excluded by the presence of Brigido's compulsory heirs (his wife and children). Consequently, Catalino lacked the legal personality or authority to sell the property to the respondents. The sale executed by Catalino was invalidated by his lack of authority, conferring no rights upon the respondents. Conversely, the sale by Brigido's heirs to the petitioners was valid, as they were the successors-in-interest and had the right to dispose of their inheritance. The Court also noted that while respondents registered their deed first, this registration could not validate a sale made by someone who had no right to sell the property, especially when the buyers were aware of the true ownership status.
Main Doctrine
Article 1544 of the Civil Code, which governs double sales of immovable property, applies only when the same property is sold by a single vendor to different vendees. It does not apply when the property is sold by two different persons, one of whom is not the owner.