This Supreme Court decision clarifies that Article 1544 of the Civil Code, concerning double sales, doesn’t apply when a property is claimed through both a prior sale and inheritance. The Court emphasized that the core issue is whether the original owner validly transferred ownership before their death. This ruling protects the rights of prior purchasers and prevents heirs from claiming property already sold, ensuring fairness in land disputes.

When a Deed Speaks: Prior Sales Trump Inheritance Claims

This case, Heirs of Ciriaco Bayog-Ang v. Florence Quinones, revolves around a contested parcel of land in Cotabato. Florence Quinones claimed ownership based on a Deed of Absolute Sale from the original owner, Ciriaco Bayog-Ang, executed in 1964. However, Bayog-Ang’s heirs later executed an Extrajudicial Settlement of Estate in 1996, including the same land and obtaining a Transfer Certificate of Title (TCT) in their names. This led to a legal battle to determine who had the rightful claim to the property.

The Regional Trial Court (RTC) initially ruled in favor of the heirs, applying Article 1544 of the Civil Code on double sales. The RTC reasoned that since the heirs were the first to register the land in good faith, they had a superior right. However, the Court of Appeals (CA) reversed this decision, holding that the land was already sold to Florence Quinones during Bayog-Ang’s lifetime, and thus, could not be included in his estate’s partition. The Supreme Court (SC) affirmed the CA’s decision, providing a significant clarification on the application of Article 1544 in relation to inheritance claims.

The Supreme Court emphasized that Article 1544 applies only when the same property is sold to different buyers by the same vendor. In this case, there was no double sale because the heirs’ claim was based on inheritance, not a subsequent sale. The pivotal question, therefore, was whether Bayog-Ang had already transferred ownership to Quinones before his death. If the sale was validly executed, the land would no longer form part of Bayog-Ang’s estate to be inherited by his heirs.

The Court then turned to Article 712 of the Civil Code, which identifies how ownership is acquired:

Art. 712. Ownership is acquired by occupation and by intellectual creation.

Ownership and other real rights over property are acquired and transmitted by law, by donation, by testate and intestate succession, and in consequence of certain contracts, by tradition.

They may also be acquired by means of prescription. (609a)

Succession, as a mode of acquiring ownership, transmits the property, rights, and obligations of a deceased person to their heirs. Crucially, heirs can only inherit what the deceased owned at the time of their death. If Bayog-Ang had already sold the land to Quinones, he no longer owned it, and his heirs could not inherit it.

Under the law on sales, particularly Article 1496 of the New Civil Code, ownership transfers to the buyer upon delivery of the property. Article 1498 further clarifies that when a sale is made through a public instrument (like a notarized Deed of Absolute Sale), the execution of that instrument is equivalent to delivery, unless the deed indicates otherwise.

The Deed of Absolute Sale in this case was a notarized document. The Supreme Court reiterated the presumption of regularity for notarized documents. As stated in Spouses Santos v. Spouses Lumbao:

It is well-settled that a document acknowledged before a notary public is a public document that enjoys the presumption of regularity. It is a prima facie evidence of the truth of the facts stated therein and a conclusive presumption of its existence and due execution. To overcome this presumption, there must be presented evidence that is clear and convincing. Absent such evidence, the presumption must be upheld.

The Court found that the heirs failed to present sufficient evidence to overcome this presumption. The RTC itself acknowledged the existence and due execution of the Deed of Absolute Sale. Therefore, in accordance with Article 1498, the execution of the notarized Deed of Absolute Sale transferred ownership of the land from Bayog-Ang to Quinones in 1964.

Having established that Quinones acquired ownership of the land, the Court addressed the issue of prescription and laches. The heirs argued that Quinones’ claim was barred because she had delayed in asserting her rights. However, the Court disagreed, pointing out that Quinones’ action was essentially one for quieting of title. An action to quiet title, where the plaintiff is in actual possession of the land under a claim of ownership, does not prescribe.

The Supreme Court cited Sapto, et al. v. Fabiana, explaining that:

The prevailing rule is that the right of a plaintiff to have his title to land quieted, as against one who is asserting some adverse claim or lien thereon, is not barred while the plaintiff or his grantors remain in actual possession of the land, claiming to be owners thereof…

Quinones and her tenant were in possession of the land, and her cause of action to quiet title only arose when the heirs obtained TCT No. T-91543 in their names, disturbing her possession. Therefore, her action, filed in 1998, was not barred by prescription.

Furthermore, the Court found no basis for laches, which requires unreasonable delay in asserting a right to the prejudice of another. The heirs were aware of Quinones’ claim and did not object when she installed a tenant on the land. The Court also dismissed the significance of Quinones’ failure to register the Deed of Absolute Sale or obtain a TCT in her name. Registration is not a means of acquiring ownership, but merely a way of notifying others of an existing claim.

The Court also emphasized that the heirs were bound by the contract between their grandfather and Quinones. Article 1311 of the New Civil Code states that contracts take effect between the parties, their assigns, and their heirs. As heirs, they inherited not only the assets but also the obligations of their predecessor-in-interest.

FAQs

What was the key issue in this case?	The central issue was whether a parcel of land should be awarded to the heirs of the original owner through inheritance or to a buyer who possessed a prior Deed of Absolute Sale. The Court needed to clarify if the principle of double sales applied when one party’s claim was based on inheritance rather than a subsequent sale.
What is Article 1544 of the Civil Code?	Article 1544 governs situations where the same property is sold to multiple buyers by the same seller. It dictates who has the superior right based on possession, registration, and good faith.
Why didn’t Article 1544 apply in this case?	Article 1544 didn’t apply because the heirs’ claim was based on inheritance, not a second sale. The Court clarified that inheritance is a different mode of acquiring property than a sale, and therefore, the double sale rule was inappropriate.
How is ownership transferred in a sale?	Ownership is transferred upon delivery of the property, as specified in Articles 1497 to 1501 of the Civil Code. When a sale is made through a public instrument, like a notarized deed, the execution of the instrument is generally equivalent to delivery.
What is the effect of a notarized Deed of Absolute Sale?	A notarized Deed of Absolute Sale is a public document that carries a presumption of regularity. It is considered prima facie evidence of the truth of the facts stated within and is proof of the document’s due execution.
What does it mean to “quiet title” to a property?	Quieting title is a legal action taken to resolve conflicting claims or remove clouds on a property’s title. It aims to ensure that the rightful owner has clear and undisputed ownership of the land.
Does an action to quiet title prescribe?	No, an action to quiet title does not prescribe if the plaintiff is in actual possession of the land under a claim of ownership. The right to seek a quiet title continues as long as the adverse claim exists.
Is registration of a property title necessary to acquire ownership?	No, registration is not a mode of acquiring ownership. It serves primarily to notify and protect the interests of third parties and to confirm the existence of an existing claim.
Are heirs bound by the contracts of their predecessors?	Yes, heirs are generally bound by the contracts entered into by their predecessors-in-interest. They inherit both the rights and obligations arising from those contracts, unless the rights and obligations are not transmissible by their nature, stipulation, or provision of law.

In conclusion, the Supreme Court’s decision underscores the importance of duly executed contracts in determining property ownership. It clarifies that inheritance cannot override a prior valid sale and reinforces the principle that heirs can only inherit what the deceased actually owned at the time of death. This ruling provides a clear framework for resolving disputes involving conflicting claims based on sale and inheritance, prioritizing the rights of those who have previously and legally purchased the property.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: HEIRS OF CIRIACO BAYOG-ANG VS. FLORENCE QUINONES, G.R. No. 205680, November 21, 2018