Article 1544 Civil Code

Carbonnell vs. Court of Appeals [January 26, 1976]

In Carbonell vs. Court of Appeals, the Supreme Court of the Philippines addressed a double sale of immovable property. The Court ruled that the buyer who first registers the sale in good faith has the superior right. Since Carbonell registered her adverse claim before Infante’s registration, and acted in good faith, she was declared the rightful owner.

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Consolidated Rural Bank vs. Court of Appeals [January 17, 2005]

In Consolidated Rural Bank vs. Court of Appeals, the Supreme Court of the Philippines ruled that when two sales involve the same property but are executed by different sellers, the principle of “he who is first in time is preferred in right” applies. The Court emphasized that a seller cannot convey what they do not own, and subsequent buyers must exercise due diligence to verify the property’s ownership.

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Rosaroso vs. Doria [June 19, 2013]

In Rosaroso vs. Doria, the Supreme Court of the Philippines addressed a double sale of property. The Court upheld the validity of the first sale to Luis Rosaroso’s children, citing the presumption of sufficient consideration. It declared the subsequent sale to Meridian Realty void, noting that Meridian was not a buyer in good faith, as it failed to investigate the property’s actual occupants.

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