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    Lu Vs Manipon

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    The Supreme Court ruled in favor of the Manipons over Francisco Lu regarding ownership of a disputed parcel of land. While Lu registered his purchase of the larger property first, he was aware that the Manipons had already purchased and occupied a portion of the land years earlier, making him a buyer in bad faith not entitled to protection. Registration does not confer absolute title, and a first registrant's claim is qualified by good faith. As the lower courts found Lu was not a good faith purchaser, the Manipons' claim based on their earlier installment purchase was stronger.

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    Lu Vs Manipon

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    aaa
    224 views1 page
    The Supreme Court ruled in favor of the Manipons over Francisco Lu regarding ownership of a disputed parcel of land. While Lu registered his purchase of the larger property first, he was aware that the Manipons had already purchased and occupied a portion of the land years earlier, making him a buyer in bad faith not entitled to protection. Registration does not confer absolute title, and a first registrant's claim is qualified by good faith. As the lower courts found Lu was not a good faith purchaser, the Manipons' claim based on their earlier installment purchase was stronger.

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    Lu vs Manipon

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    The Supreme Court ruled in favor of the Manipons over Francisco Lu regarding ownership of a disputed parcel of land. While Lu registered his purchase of the larger property first, he was aware that the Manipons had already purchased and occupied a portion of the land years earlier, making him a buyer in bad faith not entitled to protection. Registration does not confer absolute title, and a first registrant's claim is qualified by good faith. As the lower courts found Lu was not a good faith purchaser, the Manipons' claim based on their earlier installment purchase was stronger.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    224 views1 page

    Lu Vs Manipon

    Uploaded by

    aaa
    The Supreme Court ruled in favor of the Manipons over Francisco Lu regarding ownership of a disputed parcel of land. While Lu registered his purchase of the larger property first, he was aware that the Manipons had already purchased and occupied a portion of the land years earlier, making him a buyer in bad faith not entitled to protection. Registration does not confer absolute title, and a first registrant's claim is qualified by good faith. As the lower courts found Lu was not a good faith purchaser, the Manipons' claim based on their earlier installment purchase was stronger.

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    © All Rights Reserved
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    of 1

    LU VS MANIPON

    The registration of a sale of real estate will not


    protect a buyer in bad faith, for the law cannot be
    used as a shield for fraud. On the other hand, the
    preferential right of a first registrant in a double sale is
    always qualified by good faith.

    Issue

    CA affirmed the decision of the RTC.

    Who between petitioner and respondents have a


    better right of ownership over the lot in question?
    Ruling

    Facts

    May 9, 1981 - Juan Peralta executed a Deed


    of Sale by installment in favor of spouses
    Orlando and Rosita Manipon . The deed
    covered 350 square meters of the 2,078
    square-meter lot located at Barrio Dilan,
    Urdaneta, Pangasinan. The said Deed was
    not registered with the Registry of Deeds.
    June 10, 1981 - Juan Peralta mortgaged the
    aforesaid lot to Thrift Savings and Loan
    Association, Inc. (TSLAI). Since he failed to
    pay the loan, the mortgage was judicially
    foreclosed and sold to TSLAI for P62,789.18
    which was the highest bidder.
    July 15, 1988 TSLAI sold the lot in the
    amount
    of P80,000.00
    to
    Francisco
    Lu. Thereafter, he caused the subdivision of
    the said lot into five (5) lots, one of which
    includes the portion earlier sold by
    installment to the Manipons. In the interim, or
    on July 30, 1983, Juan Peralta executed
    another Deed of Sale covering a 339 sq m
    lot in favor of the Manipons after the couple
    paid a total amount of P8,000.00. The
    aforesaid Deed was however also not
    registered.
    February 26, 1990 - Lu filed the present
    action alleging therein that he is the owner of
    the lot in question including that which was
    being occupied by the respondents.

    In the Answer filed by respondents, they


    claim that Lu is a buyer in bad faith because
    even before he bought the 2,078 squaremeter lot, he knew for a fact that they
    already bought a portion of it from the
    original owner of the said lot and have been
    residing therein since 1981.

    RTC ruled in favor of the Manipons. The trial


    court ruled that Lu was not a buyer in good
    faith despite the fact that he was able to
    register his ownership of the disputed lot. He
    admitted knowing that respondents had
    constructed a house on the disputed lot.

    The Manipons have a better right.


    Lu claims to have a better right to the disputed portion
    of the real property. First, although respondents had
    bought it first, he was the first to register his purchase
    of the mother lot. Second, respondents ownership
    follows that of their vendor who mortgaged to the
    bank his title to the mother lot and failed to redeem it.
    But the Supreme Court was not convinced.
    Registration is not the equivalent of title. Under the
    Torrens system, registration only gives validity to the
    transfer or creates a lien upon the land. It was not
    established as a means of acquiring title to private
    land because it merely confirms, but does not confer,
    ownership.. Moreover, the RTC and the CA have
    correctly ruled that the preferential right of the first
    registrant of a real property in a case of double sale is
    always qualified by good faith under Article 1544 of
    the Civil Code. A holder in bad faith of a certificate of
    title is not entitled to the protection of the law, for the
    law cannot be used as a shield for fraud.
    When the registration of a sale is not made in good
    faith, a party cannot base his preference of title
    thereon, because the law will not protect anything
    done in bad faith. Bad faith renders the registration
    futile.
    Equally important, under Section 44 of the Property
    Registration Decree (Presidential Decree No. 1529),
    every registered owner receiving a certificate of title in
    pursuance of a decree of registration and every
    subsequent purchaser of registered land taking such
    certificate for value and in good faith shall hold the
    same free from all encumbrances, except those noted
    on the certificate and enumerated therein. Petitioner
    is evidently not a subsequent purchaser in good
    faith. Therefore, between the parties, respondents
    have a better right to the property based on the
    concurring factual findings of both the trial and the
    appellate courts.

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