#### Title:
**Spouses Ver Reyes vs. Bondoc et al. – Philippine Supreme Court Decision on Unregistered Land Sales**
#### Facts:
In this case, several parties laid claim to a parcel of unregistered land located in Tungtong, Las Piñas, designated as Lot 1 of Plan Psu-205035 (19,545 square meters). This land originated from Domingo Lozada and was initially held in the names of his descendants.
– **In 1965**, Nicomedes Lozada, Domingo’s son, executed a Deed of Conditional Sale over the subject property to Emma Ver Reyes.
– Terms included installment payments, and the property was to remain in Nicomedes’s ownership until the full payment.
– The sale was registered in the Registry of Property for Unregistered Lands in August 1965. Emma paid only the first installment.
– **In 1968**, Nicomedes entered a similar Agreement of Purchase and Sale with Rosario Bondoc.
– Similar payment terms as the sale to Emma.
– Agreement was registered on March 10, 1969.
– Rosario occupied, fenced, and paid taxes on the property.
– **In 1969**, a portion of the property was sold absolutely to Maria Q. Cristobal without conditions against full payment.
– Deed was registered posthumously after Nicomedes’s death in 1972.
– **In 1980**, Nicomedes’s heirs sold the remaining property to Dulos Realty and Development Corporation.
– Deed was not registered.
#### Procedural Posture:
– **1966-1975:** Series of applications and oppositions for land registration and ownership among heirs and claimants.
– Regional Trial Court (RTC) originally decided in favor of Maria and Dulos Realty based on the Deed of Absolute Sale and registration.
– Court of Appeals reversed the RTC decision, favoring Rosario Bondoc due to her earlier registration and improvements on the property.
– RTC and CA decisions led the parties to seek final resolution in the Supreme Court.
#### Issues:
1. **Validity and transfer of ownership to Emma Ver Reyes.**
2. **Bad faith on the part of Maria Cristobal and Dulos Realty.**
3. **Whether Emma and Ramon are barred by prescription or laches.**
4. **Propriety of confirming Rosario Bondoc’s title.**
5. **The registrability of Emma, Rosario’s contracts versus Maria and Dulos Realty’s contracts.**
6. **Laches/Prescription and Res Judicata as defenses.**
#### Court’s Decision:
The Supreme Court found that neither Emma’s nor Rosario’s initial contracts constituted a complete and enforceable transfer of ownership due to unfulfilled suspensive conditions (full payment).
1. **Emma and Rosario’s Contracts:** Declared as contracts to sell, not meeting conditions to transfer ownership.
– **Emma’s Deed of Conditional Sale:** Ownership not transferred pending full payment.
– **Rosario’s Agreement:** Similar constraints; no full ownership due to non-payment.
2. **Maria and Dulos Realty’s Absolute Sale Contracts:** Valid and registrable titles.
– Full consideration paid and clear contractual terms.
3. **On Better Rights:** Registrable rights of Maria and Dulos Realty superseded Rosario and Emma’s interests.
4. **Constructive Delivery and Possession Faith Claims:** Not substantiated adequately by Emma and Rosario.
The Supreme Court:
– **Denied Emma and Ramon Reyes’ petition.**
– **Granted Maria Cristobal and Dulos Realty’s petition.**
– **Reinstated the RTC’s decision favoring Maria Cristobal and Dulos Realty’s title.**
#### Doctrine:
– **Contracts to Sell:** Require fulfillment of suspensive conditions (i.e., full payment) before property ownership transfers.
– **Registration under Act No. 3344:** Without prejudice to third parties with better rights.
– **Constructive Delivery:** Requires clear indications/intent beyond mere documentation in a public instrument.
#### Class Notes:
– **Contract to Sell vs. Contract of Sale:** Essentials distinguishing contracts and ownership transfer conditions.
– Under a contract to sell, ownership transfer is contingent upon complete payment.
– Registration of unfulfilled contracts does not convey superior title compared to fulfilled absolute sales.
– **Act No. 3344:** Pertaining to the unregistered property and rights better than merely registered interest.
– **Doctrine of Laches and Prescription:** Timeliness and diligence in asserting property rights are critical.
– **Constructive Delivery:** Practical versus symbolic actions given weight in property claims.
#### Historical Background:
– **Land Registration System:** Evolved from reliance on unregistered land documents, highlighting complications in property disputes pre-Torrens system.
– **Domingo Lozada’s Estate:** Example of extended litigation over hereditary and sale transactions involving unregistered agricultural lands in Metro Manila’s evolving urban context.
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