Espiritu v.

Valerio
G.R. No. L-18018 – Dec. 26, 1965
J. Dizon

Topic: Transfer of Ownership > Double Sales > Sale of Immovables > When one sale is a forgery

Petitioner: Esperanza Espiritu and Antonia Apostol

Respondent: Francisco Valerio

Case Summary: This case concerns the sales of one parcel of land by the same vendor but in favor of
two different vendees. Respondent Valerio alleged that the deeds of sale which traced Petitioner’s
claim to Pelagia Vegilia (the common vendor) were falsified, therefore he has rightful ownership over
the property. The court ruled in favor of Respondent Valerio even though his deed of sale was
registered after Petitioners’, after having found Petitioners’ deeds of sale to be falsified and therefore
null and void

Doctrine: In case of a double sale involving immovables where one of the deed of sale was falsified,
then the vendee whose deed of sale was not falsified is the rightful owner. A buyer in a falsified deed
of sale does not acquire any right whatsoever over the property.

Facts:
 Action to Quiet Title by Respondent Francisco Valerio against Petitioners Esperanza Espiritu and
Antonia Apostol, claiming ownership over the subject parcel of land. He alleged that Petitioners were
asserting adversary rights, disturbing his possession.
 Respondent Valerio: He bought the land from Pelagia Vegilia on January 31, 1955, evidenced by a
deed of sale [Exhibit A] registered on June 15, 1955.
 Petitioners: Pelagia sold the subject land to Mariano Vegilia on May 26, 1932, as evidenced by a deed
of sale [Exhibit 2]. Then, Mariano sold the to Santiago Apostol on June 3, 1934 as evidenced by a deed
of sale [Exhibit 1]. Both deeds of sale were registered 11 days before Respondent’s Exhibit A was
registered. They then inherited the land from Santiago (Esperanza’s husband and Antonia’s father).

Who is the rightful owner of the land? – Respondent Valerio

 This case concerns the sales of one parcel of land by the same vendor but in favor of two different
vendees.
o If this is the only issue, then Petitioners would be deemed the owner of the land since their
deeds of sale were registered before that of Respondent’s.
 But there is an additional issue here of WON Exhibits 1&2 were falsified.
o Respondent alleged that Exhibit 1 is fictitious and falsified, and that Exhibit 2 is likewise null
and void because the Mariano (seller in Exhibit 2) acquired no rights whatsoever over the
land from Exhibit 1 (where Mariano was the buyer).
o If the 2 exhibits were indeed falsified, then it’s Respondent who is the rightful owner.
 Here, Exhibit 1 was held to be falsified.
o Pelagia testified that she didn’t sell the land to Mariano.
o Mariano testified that he didn’t buy the land from Pelagia.
o The thumbmark in Exhibit 1 was above the name “Anselmo Vegilia” and below Pelagia’s, so
ordinarily it will be considered as Anselmo’s. Said thumbmark was also different from
another exhibit presented (Exhibit X, but the relevance of this other exhibit was not
discussed).
 o The person who wrote Anselmo’s and Pelagia’s names were the same person, but Anselmo
could not have written it as he was certified to be physically incapacitated.
o The ink used in writing the names of Anselmo and Pelagia was different from the ink used by
the other persons who signed Exhibit 1.
o Evidence lead the court to believe that the names of Anselmo and Pelagia were written at a
much later date than the document.
 Exhibit 2 was likewise held null and void because of Mariano’s denial of having bought the land. He
could not have sold it.
 [SC just copy-pasted the decision of the CA and then indicated that there is nothing to reverse.]

Ruling: WHEREFORE, the decision appealed from is hereby AFFIRMED, with costs.

Dissent – (J. xxx):