Cano v. Cano
REITERATIONFacts
The Antecedents: Petitioners Juan and Antonina Cano claimed ownership of a parcel of land based on a donation propter nuptias allegedly made in their favor in 1962 by Feliza Baun. Respondents Arturo and Emerenciana Cano claimed ownership based on a Deed of Absolute Sale executed by Feliza in their favor in 1982, which was annotated on the Original Certificate of Title (OCT) No. 62276. Procedural History: Respondents filed an ejectment case against petitioners. The Municipal Trial in Cities (MTCC) initially dismissed the complaint, citing laches on the part of respondents and upholding the donation propter nuptias. The Regional Trial Court (RTC) initially affirmed the MTCC but later reversed its ruling, declaring respondents as owners due to the registered Deed of Absolute Sale, which it deemed a preferred right over the unregistered donation. The Court of Appeals (CA) affirmed the RTC, holding that the registered transaction should prevail. Separately, petitioners filed a quieting of title case, which the RTC also ruled in favor of respondents, again based on the registered sale. The CA affirmed this, but on the ground that the donation propter nuptias was invalid due to lack of acceptance. The Supreme Court consolidated both cases. The Petition: Petitioners contended that the non-registration of the donation propter nuptias did not make their claim inferior, that acceptance was not required for donations propter nuptias under the Civil Code, and that they had acquired ownership by acquisitive prescription. Respondents argued that they were unaware of petitioners' claim and had paid taxes on the property since their purchase.
Issue(s)
Whether the Court of Appeals erred in nullifying the donation propter nuptias executed by Feliza in favor of petitioners because of the absence of an express acceptance by the donee. Whether the Court of Appeals erred in declaring that respondents are the rightful owners of the property. Whether the Court of Appeals erred in awarding the possession of the property to respondents.
Ruling
The Supreme Court denied the petitions, affirming the Court of Appeals' ultimate conclusion that respondents are the rightful owners of the property and are consequently entitled to possession thereof, while disagreeing with certain pronouncements of the CA regarding the validity of donations propter nuptias.
Ratio Decidendi
On the nullification of the donation propter nuptias due to absence of acceptance: The Court agreed with petitioners that the Court of Appeals erred in invalidating the donation propter nuptias based on the lack of express acceptance. The donation was executed in 1962, when the Civil Code was in effect, and Article 129 of the Civil Code provided that express acceptance was not necessary for the validity of donations propter nuptias; implied acceptance was sufficient. The Court noted that the celebration of marriage and annotation of this fact in the OCT could be deemed sufficient implied acceptance. However, this ruling on the validity of the donation did not alter the ultimate outcome of the case. On the declaration of respondents as rightful owners: Despite the potential validity of the donation propter nuptias, the Court affirmed the CA's ruling that respondents are the rightful owners. This is because the prior unregistered donation propter nuptias does not bind third persons, such as respondents, who are innocent purchasers for value. Article 709 of the Civil Code and Sections 51 and 52 of P.D. 1529 mandate that rights over immovable property must be inscribed or annotated to prejudice third persons. The act of registration is the operative act to convey or affect the land concerning third parties. Since the Deed of Absolute Sale in favor of respondents was registered, it conveyed ownership to them. Petitioners failed to prove that respondents had actual knowledge of their unregistered interest at the time of purchase; mere possession is insufficient. On the award of possession of the property to respondents: In view of the Court's affirmation of respondents' ownership, it follows that they are entitled to possession of the land. Petitioners' claim of ownership based on the donation propter nuptias and acquisitive prescription was defeated by the registered Deed of Absolute Sale. Therefore, petitioners have no right to remain on the property, regardless of whether their prior possession was tolerated. The Court also clarified that acquisitive prescription does not apply to registered land under Section 47 of P.D. 1529.
Main Doctrine
The registered Deed of Absolute Sale in favor of innocent purchasers for value prevails over a prior unregistered donation propter nuptias, as registered land cannot be acquired by prescription or adverse possession.