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SPRING HOMES SUBDIVISION CO., INC., SPOUSES PEDRO L. LUMBRES AND REBECCA T.

ROARING vs. SPOUSES PEDRO TABLADA, JR. AND ZENAIDA TABLADA


G.R. No. 200009, 23 January 2017, J. Peralta

Ownership of an immovable property which is the subject of a double sale shall be


transferred: (1) to the person acquiring it who in good faith first recorded it in the Registry of
Property; (2) in default thereof, to the person who in good faith was first in possession; and (3) in
default thereof, to the person who presents the oldest title, provided there is good faith. The
requirement of the law then is two-fold: acquisition in good faith and registration in good faith.

Facts:

In 1996, Spring Homes entered into a Deed of Absolute Sale with the Spouses Tablada over
a parcel of land located at Lot No. 8, Block 3, Spring Homes Subdivision, Barangay Bucal, Calamba,
Laguna. The Spouses Tablada, however, were not able to register the property under their name
because Spring Homes was not able to give them the title over the same.

In 2000, Spring Homes likewise entered into a Deed of Sale over the same property. Hence,
the Spouses Tablada filed a complaint for Nullification of Title, Reconveyance and Damages against
Spring Homes and the Spouses Lumbres. Later, however, the Spouses Tablada dropped Spring
Homes from the case.

The RTC dismissed the Spouses Tabladas complaint. The CA reversed the RTC ruling and
held that the first sale between Spring Homes and the Spouses Tablada must still be upheld as
valid, contrary to the contention of the Spouses Lumbres that the same was not validly
consummated due to the Spouses Tablada's failure to pay the full purchase price of P409,500.00.

Issue:

Who, between the two spouses herein, properly acquired ownership over the subject
property.

Ruling:

The Spouses Tablada properly acquired ownership over the subject property.

The principle of primus tempore, potior jure (first in time, stronger in right) gains greater
significance in case of a double sale of immovable property. Thus, the Court has consistently ruled
that ownership of an immovable property which is the subject of a double sale shall be transferred:
(1) to the person acquiring it who in good faith first recorded it in the Registry of Property; (2) in
default thereof, to the person who in good faith was first in possession; and (3) in default thereof, to
the person who presents the oldest title, provided there is good faith. The requirement of the law
then is two-fold: acquisition in good faith and registration in good faith. Good faith must concur
with the registration that is, the registrant must have no knowledge of the defect or lack of title of
his vendor or must not have been aware of facts which should have put him upon such inquiry and
investigation as might be necessary to acquaint him with the defects in the title of his vendor. If it is
shown that a buyer was in bad faith, the alleged registration they have made amounted to no
registration at all.
The first buyers of the subject property, the Spouses Tablada, were able to take said
property into possession but failed to register the same because of Spring Homes' unjustified
failure to deliver the owner's copy of the title whereas the second buyers, the Spouses Lumbres,
were able to register the property in their names. But while said the Spouses Lumbres successfully
caused the transfer of the title in their names, the same was done in bad faith because they knew
that the subject lot was previously sold to the Spouses Tablada.

Indeed, knowledge gained by the first buyer of the second sale cannot defeat the first
buyer's rights except only as provided by law, as in cases where the second buyer first registers in
good faith the second sale ahead of the first. Such knowledge of the first buyer does bar her from
availing of her rights under the law, among them, first her purchase as against the second buyer.
But conversely, knowledge gained by the second buyer of the first sale defeats his rights even if he is
first to register the second sale, since such knowledge taints his prior registration with bad faith.