Badilla v. Bragat
REITERATIONFacts
The Antecedents: Spouses Pastrano were original owners of Lot No. 19986. They sold it to Eustaquio Ledesma, Jr. on November 18, 1968. In 1970, Ledesma sold a 200 sq. m. portion to Spouses Badilla on installment, transferring possession. On April 18, 1978, Spouses Bragat bought 991 sq. m. from Ledesma. On May 5, 1984, Spouses Pastrano executed a Deed of Absolute Sale of the entire 1,015 sq. m. lot to Fe Bragat, and Azur Pastrano reported the owner's duplicate copy of OCT No. P-2035 as lost. Bragat obtained a new owner's copy. On October 2, 1987, Spouses Pastrano executed another Deed of Sale of the same lot to Bragat, leading to the cancellation of OCT No. P-2035 and the issuance of TCT No. T-47759 in Bragat's name. Procedural History: On March 7, 1991, Bragat demanded Spouses Badilla vacate. Spouses Badilla refused, asserting their prior purchase. Bragat filed a Complaint for Recovery of Possession and Damages on June 5, 1992. Spouses Badilla filed a Complaint for Quieting of Title, Declaration of Nullity of TCT No. T-47759 and Damages on June 11, 1992. The cases were consolidated. The RTC ruled in favor of Bragat, finding her title valid and Spouses Badilla lacking evidence. The CA affirmed the RTC but modified the ruling, ordering reconveyance of 24 sq. m. to Spouses Badilla and deleting awards for damages and attorney's fees. The CA remanded the case for determination of the 24 sq. m. portion. The Petition: Spouses Badilla filed a petition for review on certiorari, arguing ownership was transferred to them in 1970, that the title was not lost but delivered to them, and that Bragat committed fraud in obtaining a new title and in the October 2, 1987 sale, as Profitiza Pastrano was already deceased. Bragat countered that the October 2, 1987 sale was a re-execution of the May 5, 1984 sale and that Badillas' evidence was post-dating her title.
Issue(s)
Whether the Supreme Court can re-examine the factual findings of the Court of Appeals. Whether ownership of the 152-square-meter portion of Lot No. 19986 was transferred to Spouses Badilla in 1970. Whether the Deed of Sale dated October 2, 1987, executed by Spouses Pastrano in favor of Fe Bragat, is void. Whether TCT No. T-47759 issued to Fe Bragat is valid.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED and SET ASIDE. Transfer Certificate of Title No. T-47759 is DECLARED VOID, and in its place, two new transfer certificates of title are ORDERED ISSUED: one in the name of Spouses Magdalino and Cleofe Badilla covering 152 sq. m., and another in the name of Fe Bragat covering the remaining 863 sq. m., based on survey plans.
Ratio Decidendi
On the re-examination of factual findings: While generally factual findings of the CA affirming the RTC are binding, the Supreme Court may review them when there is a misapprehension of facts, the judgment is belied by the evidence, or relevant facts were not noticed, which, if considered, would justify a different conclusion. In this case, the Court found that the lower courts misapprehended the fact that ownership passed to Spouses Badilla upon their purchase from Ledesma, necessitating a review of the facts. On the transfer of ownership to Spouses Badilla: Ownership of the 152-square-meter portion was transferred to Spouses Badilla in 1970 when Ledesma sold it to them. This transfer of ownership occurred upon the delivery of the property, even if the sale was verbal and on installment, as there was no stipulation reserving ownership until full payment. The delivery of the owner's duplicate copy of OCT No. P-2035 further evidenced the intent to transfer ownership. The verbal sale, being partially consummated by delivery and partial payment, is enforceable and not barred by the Statute of Frauds. On the validity of the Deed of Sale dated October 2, 1987: This deed of sale is void because it was simulated. At the time of its execution, Spouses Pastrano no longer owned the property, having sold it to Ledesma in 1968. Bragat herself knew this, as she had previously purchased a portion from Ledesma. Furthermore, one of the signatories, Profitiza Pastrano, was already deceased at the time of the sale, rendering the sale void for lack of a valid subject matter and due to fraud. On the validity of TCT No. T-47759: TCT No. T-47759, issued to Fe Bragat, is void because it was based on simulated sales where the vendor (Pastrano) lacked ownership. Bragat's title should have been derived from her purchase from Ledesma on April 18, 1978, which excluded the portion already sold to Spouses Badilla. In situations of multiple sales without registration in good faith, Article 1544 of the Civil Code dictates that ownership belongs to the one who first took possession in good faith. Since Bragat's subsequent purchases were simulated and she was aware of Spouses Badilla's prior possession, her claim to the portion occupied by Spouses Badilla is invalid.
Main Doctrine
In cases of multiple sales of the same property where no registration in good faith is made by any buyer, ownership is determined by prior possession in good faith. A sale is void if the vendor lacks ownership at the time of sale, and the vendee's knowledge of this lack of ownership negates good faith.