45. 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:
o 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.
 
o 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.
o The RTC dismissed the Spouses Tablada’s 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.