Practice question
An earlier sale is established to be valid and partly performed, including buyer possession, but its first document was unnotarized. A later buyer says lack of notarization alone means there can never be two valid sales. What does Cesa indicate?
- Every private sale document is nonexistent
- Possession can never be evidence
- Only notaries can sell land
- A later deed erases every earlier contract
- The actual validity and performance must be examined; absence of notarization alone does not necessarily eliminate the earlier sale
Legal references
- Spouses Cesa v. Spouses Brucelas and Del Rosario, G.R. No.255564, March 5, 2025, MAIN decision: https://lawphil.net/judjuris/juri2025/mar2025/gr_255564_2025.html
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