Vicente Sapto, Laureana Sapto, and Dora (Bagoba) vs. Apolonio Fabiana, G.R. No. L-6714 (1959)
### Facts:
1. **Ownership and Succession**:
– Sapto (a Moro) was the registered owner of a parcel of land in Alambre, Toril, Davao City under Transfer Certificate of Title No. T-5701 (0-28).
– Upon Sapto’s death, he left his children Samuel, Constancio, and Ramon as heirs.
– Ramon predeceased his brothers, leaving no heirs.
2. **Deed of Sale**:
– On June 6, 1931, Samuel and Constancio sold a four-hectare portion of the land to Apolonio Fabiana for P245.00.
– The sale was approved by the Provincial Governor of Davao but was never registered.
– Fabiana took possession of the land and maintained possession since 1931.
3. **Subsequent Heirs**:
– Constancio died without issue.
– Samuel married Dora (Bagoba) and upon his death, was survived by his widow and children, Laureana and Vicente Sapto.
4. **Legal Action**:
– On October 19, 1954, Samuel’s widow and children filed an action in the Court of First Instance (CFI) of Davao for the recovery of the parcel of land.
5. **Lower Court Decision**:
– The CFI ruled that the sale was valid and binding despite not being registered and ordered the appellants to execute a necessary deed of conveyance for Fabiana.
6. **Appeal**:
– Plaintiffs appealed to the Supreme Court, asserting that the unregistered sale should not bind them and challenging the prescription period for such a claim.
### Issues:
1. **Validity of Unregistered Sale**:
– Whether the deed of sale, though never registered, is valid and binding on the appellants.
2. **Prescription of Action**:
– Whether the action for conveyance had prescribed given that twenty years had passed since the original sale.
### Court’s Decision:
1. **Validity of Unregistered Sale**:
– The Supreme Court affirmed the lower court’s decision, reiterating that registration of the deed of sale is not necessary for the validity of the sale between the original parties or their heirs.
– Actual notice and possession suffice to bind the parties.
– Since Fabiana had been in possession of the land and no rights of third parties were involved, the lack of registration did not invalidate the sale.
2. **Prescription of Action**:
– The Supreme Court dismissed the claim of prescription, citing that the action to quiet title is imprescriptible as long as the claimant is in possession.
– The right to have title quieted remains while the plaintiff or their predecessors are in actual possession, protecting them from adverse claims.
– This aligns with Article 480 of the New Civil Code and relevant American jurisprudence.
### Doctrine:
– **Unregistered Sales**:
– Under Section 50 of the Land Registration Act, a deed of sale not registered still operates as a valid contract between the parties, binding them and their heirs.
– Only registration affects third-party rights and subsequent transactions.
– **Action to Quiet Title**:
– Actions to remove a cloud on title are imprescriptible when the claimant is in possession of the property, and can be asserted until such right is disturbed.
### Class Notes:
– **Unregistered Deeds**: An unregistered deed is still valid and binding between the original parties and their heirs.
– **Prescription of Actions**: Actions to quiet title remain valid and do not prescribe as long as the claimant remains in possession.
– **Legal Precedents**: References include Obras Pias vs. Devera Ignacio (17 Phil. 45), Gustilo vs. Maravilla (48 Phil. 442), Galasinao vs. Austria (51 Off. Gaz. No. 6, 2874), and others reaffirming these principles.
– **Article 480, Civil Code**: Reflects this non-prescriptive nature for actions to quiet title.
### Historical Background:
– **Torrens System Context**:
– The case underscores the separation between registration, which provides public notice and protects third parties, and the validity of private transactions between parties.
– It highlights the Torrens system’s intent to prevent fraud and misuse by ensuring registered land transactions are transparent and protected.
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