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JUANITA NAVAL v. CA

FACTS:

The case involves a dispute over a parcel of land in Camarines Sur. Ildefonso Naval sold the land to Gregorio Galarosa in 1969, and the sale was registered. Gregorio later sold portions of the land to the respondents. However, Juanita Naval, another claimant, filed a complaint for recovery of possession against the respondents. The Municipal Circuit Trial Court (MCTC) ruled in favor of Juanita Naval, declaring her as the legal owner of the land. The decision was affirmed by the Regional Trial Court (RTC), but reversed by the Court of Appeals. The Court of Appeals held that the prior registration of the sale between Ildefonso and Gregorio gave constructive notice to subsequent buyers, granting the respondents superior rights over the land. Juanita Naval filed a petition for review before the Supreme Court, challenging the decision of the Court of Appeals.

ISSUES:

  1. Whether Article 1544 of the Civil Code is applicable to unregistered land.

  2. Whether the registration of the first sale under Act No. 3344 can defeat the right of the second buyer.

  3. Whether or not the registered owner of a Torrens title can be compelled to reconvey the registered property to its true owners.

  4. Whether or not an action for reconveyance prescribes when the plaintiff is in possession of the land to be reconveyed.

RULING:

  1. Article 1544 of the Civil Code is not applicable to unregistered land.

  2. The registration of the first sale under Act No. 3344 can defeat the right of the second buyer.

  3. Yes, the registered owner of a Torrens title can be compelled to reconvey the registered property to its true owners. The Court ruled that reconveyance does not set aside or re-subject to review the findings of fact of the Bureau of Lands. Instead, what is sought is the transfer of the property or its title to its rightful or legal owner, or to the one with a better right.

  4. An action for reconveyance does not prescribe when the plaintiff is in possession of the land to be reconveyed. The Court held that if a person claiming to be the owner of the property is in actual possession of it, the right to seek reconveyance, which seeks to quiet title to the property, does not prescribe. The reason for this is that one who is in actual possession of a piece of land claiming to be the owner thereof may wait until his possession is disturbed or his title is attacked before taking steps to vindicate his right.

PRINCIPLES:

  • The registration contemplated under Article 1544 refers to registration under the Torrens System. (Carumba v. Court of Appeals)

  • Act No. 3344 provides for the registration of instruments on unregistered land. Registration by the first buyer creates constructive notice to the second buyer. (Bautista v. Fule)

  • The issue of good faith or bad faith of the buyer is only relevant to registered land. In the case of unregistered land, subsequent buyers purchase at their peril. (Rayos v. Reyes)

  • No one can give what one does not have. Ownership is different from a certificate of title. A certificate of title is merely evidence of ownership, it does not create or vest title. (Various cases cited)

  • Reconveyance does not set aside or re-subject to review the findings of fact of the Bureau of Lands. It seeks the transfer of the property or its title to its rightful owner.

  • An action for reconveyance does not prescribe when the plaintiff is in possession of the land to be reconveyed. The right to seek reconveyance does not start until the possessor's possession is disturbed or their title is attacked.