Tamayao v. Lacambra
REITERATIONFacts
The Antecedents: The case involves a parcel of land (Lot No. 2930) originally owned by Vicente Balubal. His heirs, Jose and Tomasa Balubal, sold the entire lot to Juan Lacambra in 1962 via an Extrajudicial Settlement and Sale. Juan's heirs (heirs of Lacambra) took possession and exercised acts of ownership. In 1980, some of Juan's heirs sold a 5/14 pro indiviso share to Spouses Rogelio and Felipa Tamayao. Subsequently, in 1981, the heirs of Balubal (claiming they never sold the land) executed an Extrajudicial Settlement of a Parcel of Land with Sale of the entire Lot No. 2930 in favor of Spouses Tamayao. This latter sale led to the cancellation of the original title and the issuance of TCT No. T-54668 in the name of Spouses Tamayao. Procedural History: The heirs of Lacambra filed a complaint for annulment of the 1981 sale and cancellation of TCT No. T-54668. Separately, some heirs of Lacambra filed a complaint for legal redemption. The RTC annulled the 1981 sale and TCT No. T-54668, declared the 1962 sale valid, and recognized the heirs of Lacambra as owners of 9/14 and Spouses Tamayao as owners of the 5/14 share they initially bought. The CA affirmed the RTC's decision, holding that the 1981 sale was void because the heirs of Balubal were no longer owners, and even if Article 1544 applied, Spouses Tamayao were in bad faith. The Petition: Spouses Tamayao (petitioners) assailed the CA's decision, arguing that the CA erred in upholding the 1962 sale and in invalidating the 1981 sale and their TCT, claiming they were innocent purchasers for value.
Issue(s)
Whether the Court of Appeals erred in upholding the first sale (1962) in favor of Juan Lacambra and affirming the heirs of Lacambra's right to own and possess Lot No. 2930. Whether the Court of Appeals erred in invalidating the subsequent sale (1981) between the heirs of Balubal and Spouses Tamayao and the Transfer Certificate of Title issued pursuant thereto.
Ruling
The Petition is DENIED. The Decision dated May 23, 2018, and Resolution dated January 14, 2019, of the Court of Appeals are AFFIRMED.
Ratio Decidendi
On the validity of the first sale (1962) and the rights of the heirs of Lacambra: The Court affirmed the findings of the lower courts that Jose and Tomasa Balubal validly sold Lot No. 2930 to Juan Lacambra in 1962. The Extrajudicial Settlement and Sale, being a notarized public document, enjoys the presumption of regularity and due execution. The petitioners' claim of forgery was unsubstantiated by clear and convincing evidence. Furthermore, the execution of the public instrument constituted constructive delivery of the property, and the subsequent acts of possession and exercise of ownership by Juan and his heirs further confirmed the consummation of the sale. The failure to register the 1962 sale did not render it void, as registration is not essential for validity between the parties, but rather for binding third parties. The Court reiterated that a sale is a consensual contract perfected by mere consent, and ownership is transferred by delivery. On the invalidity of the third sale (1981) and the rights of Spouses Tamayao: The Court upheld the invalidation of the 1981 sale between the heirs of Balubal and Spouses Tamayao. Applying the principle of nemo dat quod non habet (no one can give what one does not have), the heirs of Balubal, having already sold the property in 1962, had no right to sell it again in 1981. Consequently, Spouses Tamayao could not acquire any right from a void sale. The Court found that Spouses Tamayao were purchasers in bad faith. They were aware of the prior sale to Juan Lacambra and the possession of the property by his heirs, as evidenced by their own purchase of a 5/14 share from the heirs of Lacambra in 1980. Their subsequent purchase of the entire lot from the heirs of Balubal, despite this knowledge, tainted their registration with bad faith. Therefore, they could not claim protection as innocent purchasers for value. The TCT issued in their name was also declared void because the owner's duplicate copy of the original title was never lost but was delivered to Juan in 1962, making the reconstitution and subsequent issuance of a new title void. The Court also clarified that Article 1544 (double sales) does not apply when the second sale is made by someone who is no longer the owner.
Main Doctrine
The registration of a sale, while necessary to bind third parties, does not confer ownership. Ownership is transferred by delivery. A subsequent sale by a vendor who no longer owns the property is void, and the second buyer, even if they register the sale, cannot acquire ownership if they acted in bad faith.