This Supreme Court decision clarifies that a properly executed deed of sale transfers ownership of land, even if the buyer fails to register the sale immediately. The case underscores the importance of due diligence in land transactions and registration’s role in providing notice, not in creating ownership itself. This ruling protects the rights of buyers who have legitimate deeds, ensuring that heirs cannot claim land already sold by their predecessors.

From Farmland to Family Feud: Whose Claim Prevails?

This case revolves around a contested parcel of land in Midsayap, Cotabato, sparking a legal battle between Florence Quinones, who possessed a deed of sale from the original owner, Ciriaco Bayog-Ang, and the Heirs of Ciriaco Bayog-Ang, who subsequently titled the land in their names through an extrajudicial settlement. Florence claimed that Bayog-Ang sold her the land in 1964, providing a Deed of Absolute Sale as evidence. The heirs, however, argued they had no knowledge of this sale and registered the land in their name after Bayog-Ang’s death, claiming it as part of their inheritance. The central legal question is: Who has the superior right to the land – the buyer with an unregistered deed or the heirs with a registered title?

The Regional Trial Court (RTC) initially sided with the heirs, applying Article 1544 of the Civil Code on double sales, reasoning that the heirs registered the land first in good faith. However, the Court of Appeals (CA) reversed this decision, emphasizing that ownership transfers upon the execution of a valid deed of sale and that registration does not create ownership. The Supreme Court took up the case to resolve this conflict, focusing on whether the CA erred in reversing the RTC’s findings of prescription and laches.

The Supreme Court emphasized that Article 1544, concerning double sales, was improperly applied by the RTC. The High Court explained that it requires the same property to be sold to different buyers. In this case, the heirs did not purchase the land; they inherited it. Therefore, the core issue was whether Bayog-Ang validly transferred ownership to Florence before his death. If so, the land would not form part of his estate to be inherited.

Article 712 of the Civil Code identifies the modes of acquiring ownership. Tradition as a result of contracts is a method of transferring ownership. The court highlighted Article 1496 of the Civil Code, which stipulates that ownership passes to the buyer upon delivery of the thing sold. Articles 1497 and 1498 further clarify that delivery occurs when the buyer gains control or when a public instrument (like a notarized deed) is executed, unless the deed states otherwise.

The Deed of Absolute Sale presented by Florence was a notarized document. Such a document, according to Section 19, Rule 132 of the Rules of Court, is a public document. The court cited Spouses Santos v. Spouses Lumbao, emphasizing the presumption of regularity of public documents. This presumption means the deed is considered prima facie evidence of the facts stated within it, including the transfer of ownership. The burden then shifted to the heirs to present clear and convincing evidence to overcome this presumption, which they failed to do.

The Supreme Court pointed out that the RTC itself acknowledged the existence and due execution of the Deed of Absolute Sale. Therefore, based on Article 1498, the execution of the notarized deed effectively transferred ownership from Bayog-Ang to Florence in 1964. From a legal point of view, the High Tribunal also declared that the action was not barred by prescription or laches. The Court agreed with the CA and RTC that the action was for quieting of title, which does not prescribe.

Regarding laches, the court found that the elements were not met. There was no unreasonable delay in asserting the claim, as Florence and her successors were in possession of the land. The heirs were also aware of Florence’s claim. These facts led the Supreme Court to conclude that Florence’s right to the property was valid and enforceable.

The Supreme Court reiterated that registration is not a means of acquiring ownership, but a way of notifying the world of an existing ownership claim. As the CA correctly pointed out, the act of registration only confirms the existence of that right, providing notice to the public. The heirs could not claim ignorance of Florence’s right, as they stand in the shoes of their predecessor, Bayog-Ang, who entered into the sales contract. Article 1311 of the Civil Code states that contracts bind the parties, their assigns, and their heirs. The heirs are thus bound by the sale made by Bayog-Ang, unless the contract stipulated otherwise, which was not the case here.

FAQs

What was the key issue in this case?	The central question was who had the superior right to a parcel of land: the buyer with a deed of sale or the heirs of the seller who had the land titled in their names after the seller’s death. The Supreme Court determined that a valid deed of sale transfers ownership, even if unregistered.
What is a Deed of Absolute Sale?	A Deed of Absolute Sale is a legal document that proves the transfer of ownership of a property from a seller to a buyer. It becomes a public document when notarized.
Does registration create ownership?	No, registration does not create ownership. It only serves as notice to the public that a particular person or entity owns the property and protects the interests of strangers to a given transaction.
What is the significance of a notarized document?	A notarized document, like a Deed of Absolute Sale, is considered a public document and carries a presumption of regularity. It is considered prima facie evidence of the truth of the facts stated and is self-authenticating.
What is the principle of laches?	Laches is the failure or neglect, for an unreasonable length of time, to do something which should have been done, or to claim or enforce a right at a proper time. The court ruled laches did not apply because there was no unreasonable delay, and they were in possession of the land.
What is the role of heirs in contracts made by their predecessors?	Heirs are generally bound by the contracts entered into by their predecessors-in-interest, according to Article 1311 of the Civil Code. They inherit the rights and obligations arising from those contracts, unless the contract stipulates otherwise.
What is an action for quieting of title?	An action for quieting of title is a legal proceeding to remove any cloud, doubt, or uncertainty over the title to real property. The lawsuit aims to prevent future disputes about the ownership of the land.
How does prescription relate to actions for quieting of title?	Prescription is the acquisition of ownership or other rights through the continuous passage of time. However, the court stated that an action for quieting of title is imprescriptible if the plaintiff is in possession of the property.

The Supreme Court’s decision reinforces the principle that ownership transfers upon the execution of a valid deed of sale, not merely upon registration. This ruling underscores the importance of due diligence and timely registration to protect one’s rights in real estate transactions. It serves as a reminder that heirs cannot inherit what their predecessors no longer own.

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