Baladia y Esplago v. Spouses Bersabe

 

Baladia y Esplago v. Spouses Bersabe

G.R. No. 221206

June 16, 2021

 

FACTS:

The case involves a complaint for Nullity of Sale, Cancellation of Certificate of Title, and damages filed by the respondents, Rosalind Dichoso Bersabe and Alberto G. Bersabe, Jr., against the petitioners, Mariano Baladia and Marietta Baladia-Dador, as well as other defendants. The complaint alleges that the respondents and one of the defendants, Julieta Baladia, were involved in a previous case for Sum of Money, which was decided in favor of the respondents. The decision became final and the respondents moved for execution of judgment. The property in question was levied and sold at a public auction, with the respondents being the highest bidder. However, when they tried to transfer the title of the property in their name, they discovered that it had been sold to the other defendants, spouses Ruben and Niña Cañeso, who were able to obtain a Free Patent Certificate of Title. The petitioners, on the other hand, claim that the property was previously owned by their parents and was sold to the spouses Cañeso. They argue that they were not aware of the previous mortgage and the favorable decision obtained by the respondents. The Regional Trial Court (RTC) ruled in favor of the respondents, declaring them as the lawful owners of the property and ordering the cancellation of the title in the name of the spouses Cañeso. The petitioners and the spouses Cañeso appealed to the Court of Appeals (CA), which affirmed the RTC's decision with modifications.

ISSUE:

Whether the CA erred in affirming the RTC's ruling that the subject property belongs to the respondents.

HELD:

No. Considering that the property was unregistered at the time it was sold, either to the spouses Bersabe or to the spouses Ca eso, the applicable law is Act No. 3344, which provides for the registration of all instruments on land neither covered by the Spanish Mortgage Law nor the Torrens System. Under Act No. 3344, registration of instruments affecting unregistered lands is without prejudice to a third party with a better right. The aforequoted phrase has been held by this Court to mean that the mere registration of a sale in one's favor does not give him any right over the land if the vendor was not anymore the owner of the land having previously sold the same to somebody else even if the earlier sale was unrecorded. The rights vested in the spouses Bersabe by the execution sale and the confirmation thereof constitute a better right which is protected by Act No. 3344.