**Balatbat vs. Court of Appeals and Spouses Repuyan: A Study in Property Sale and Buyer Rights**
### Facts:
The narrative of this legal contest unfolds with a partition claim filed by Aurelio A. Roque in 1977, resulting in a court decision in 1979 that divided ownership of a property among Roque and his four children. The decree was finalized without objection, and a new title reflecting the division was issued later that year.
Roque sold his majority stake (6/10) in the property to the Repuyan spouses in 1980. However, the Repuyans’ failure to fully pay the agreed price prompted Roque to attempt a contract rescission, igniting a series of legal battles that weaved through the Philippine legal system. Despite subsequent court rulings affirming the sale and enjoining Roque to comply with its terms, a second sale of the same property was made to Clara Balatbat in 1982. This action set the stage for a complex legal question about the property’s rightful ownership.
Balatbat’s subsequent moves to cement her claim, including a motion to intervene in the rescission case and the issuance of a writ of possession in her favor, were impeded by the legal recognition of the Repuyans’ prior claim. The courts found that the Repuyans’ earlier acquisition and their annotation of an adverse claim on the title sufficiently protected their rights, despite Balatbat’s later registration and physical possession of the property.
### Issues:
1. Whether the sale to the Repuyans was merely executory and not consummated due to partial payment and lack of delivery.
2. Whether there was a double sale as per Article 1544 of the Civil Code.
3. Whether Balatbat was a buyer in good faith.
4. Whether the appellate court erred in considering evidence from the Repuyans that was not formally offered at trial.
### Court’s Decision:
1. The court found the sale to the Repuyans consummated and binding, as the balance was payable upon the property’s partition and subdivision, and delivery was constituted by the transfer of the title document.
2. There was indeed a double sale, but priority was given to the Repuyans for having first recorded their claim through an adverse claim annotation.
3. Balatbat could not be considered a buyer in good faith as she had ample opportunity to discover the claims against the property before her purchase.
4. The court did not address the issue of evidence directly, focusing instead on the procedural history and substantive legal principles to affirm the appellate court’s decision.
### Doctrine:
– The case reinforces the doctrine surrounding double sales of immovable property, emphasizing the priority of the first buyer to register the sale in good faith.
– It also clarifies the consummation of a sale as not necessarily contingent upon full payment but upon fulfillment of conditions agreed by the parties.
### Class Notes:
1. **Double Sale:** Article 1544, Civil Code – Determines ownership in cases of double sale based on priority of registration, possession in good faith, or oldest title in good faith.
2. **Good Faith in Purchases:** A purchaser must exercise due diligence in verifying a property’s status and claims before acquisition to be considered a buyer in good faith.
3. **Effects of Non-Payment:** Non-payment of the purchase price does not automatically rescind a contract of sale unless specifically stipulated or upon court rescission under Article 1191 of the Civil Code.
4. **Adverse Claim:** The annotation of an adverse claim on a property title serves as warning to third parties and establishes a claimant’s rights against subsequent buyers.
### Historical Background:
This case is situated within the broader legal context of property sales in the Philippines, where issues of good faith, double sale, and the effects of annotations on titles pose recurrent legal challenges. It illustrates the complexities involved in property transactions and the critical importance of due diligence from all parties involved.
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