RUFINA BAUTISTA, ALFREDO JR., LUZVIMINDA, MARIZA, JOSEPHINE, ALEJANDRO and AMELITA, all surnamed VALDEZ, vs. HON. COURT OF APPEALS, HON. MARINA L. BUZON, SPOUSES DONALD SALVADOR and CRESENCIA SALVADOR.
- G.R. Number: G.R. No. 106042
- Promulgated: 1994-02-28
- Ponente: Nocon, J.
Doctrine
Good faith in land purchases is a question of intention to be ascertained from surrounding circumstances.
The defence of in pari delicto applies only when the parties are similarly situated; unequal fault defeats the doctrine.
Trial court findings on witness credibility are accorded respect because trial courts are better judges of witness demeanor.
Facts
This is a petition for review of a Court of Appeals decision in a prior ruling (CA-G.R. CV No. 31620).
Trial court found private respondents could not register the deed of sale after paying the last installment because the vendor could not locate his copy of the transfer certificate of title; the Court of Appeals respected that finding.
Private respondents had uninterrupted possession of the property, which may have caused complacency but did not render them equally blameworthy.
The Supreme Court dismissed the petition. Four justices concurred in the decision.
Issues
Whether petitioners bought the land in good faith, to be determined from surrounding circumstances.
Whether the parties are in pari delicto such that equitable relief should be denied.
Ruling
The Court held that good faith is a question of intention proven by surrounding circumstances and proceeded to analyze the purchases accordingly. Petitioners' challenge was dismissed.
The parties are not in pari delicto because they were not similarly situated; private respondents were not equally blameworthy for failing to register.
The Court respected the trial court's factual finding on respondents' inability to register due to the vendor's missing title copy, as the trial court is better placed to assess witness demeanor.
Keywords
G.R. No. 106042, recovery of possession of property, double sale, Article 1544 of the New Civil Code, purchasers in bad faith, gross negligence amounting to bad faith, duty to inquire, actual, visible and public possession, bona fide purchaser, certificate of title, De Guzman, Jr. v. Court of Appeals, 156 SCRA 701, Incala vs. Mendoza, CA-G.R. No. 13677-R, De Jesus vs. Revilla, CA-G.R. No. 13562-R, Marcelino vs. Manikan, CA-G.R. No. 32792-R, Conspecto vs. Fruto, 31 Phil. 144, doctrine of in pari delicto, extrajudicial settlement with absolute sale, Transfer Certificate of Title (TCT) No. 343919, legal heir, Deed of Absolute Sale