SC invalidates property sale amid buyer’s knowledge of defect



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The Supreme Court (SC) has invalidated a property sale in Tacloban City, ruling that the buyer knew the seller was not the real owner of the land.
In a decision dated 26 February, the court’s Third Division canceled the sale from Bayani S. Cerilla to Edward C. Ciacho, stating that Ciacho was aware the properties did not belong to the seller.
The case involves two parcels of land inherited by Adolfo T. de Guia. When the properties were about to be foreclosed due to unpaid debt, De Guia asked Cerilla to help pay off the mortgage. A deed of sale was signed, and the land titles were transferred to Cerilla’s name, but a few months later, the two signed another agreement to re-sell the land to De Guia.
Cerilla later asked Ciacho for a loan, using the properties as collateral. When Cerilla was unable to repay the loan, he signed a deed of sale to Ciacho but asked him not to transfer the properties to his name. Despite this, Ciacho registered the lands under his own name. De Guia then filed a case with the Regional Trial Court (RTC) to invalidate the sale.
The RTC and the Court of Appeals both ruled in De Guia’s favor, stating that Cerilla had no authority to sell the properties as he was just an “accommodation party,” or someone who helped with the paperwork but was not the true owner. The courts also said that Ciacho was not an innocent buyer because he knew that De Guia had a legal claim on the properties.
The Supreme Court upheld their rulings, saying that for a sale to be valid, the parties must have a clear intention to transfer ownership. In this case, there was no real intention to transfer ownership from De Guia to Cerilla.