Adoracion Rosales et al. vs. Leonarda Burgos et al G.R. No. 143573 January 30, 2009
FACTS:
Petitioner Adoracion Rufloe is the wife of Angel Rufloe, now deceased, while co-petitioners Alfredo and Rodrigo are their children. During the marriage of Adoracion and Angel, they acquired a 371-square meter parcel of land located at Barangay Bagbagan, Muntinlupa, which is the subject of the present controversy. Sometime in 1978, respondent Elvira Delos Reyes forged the signatures of Adoracion and Angel in a Deed of Sale dated to make it appear that the disputed property was sold to her by the spouses Rufloe. On the basis of the said deed of sale, Delos Reyes succeeded in obtaining a title in her name. IThe Rufloes filed a complaint for damages against Delos Reyes alleging that Angel Rufloe died in 1974, which was four (4) years before the alleged sale in favor of Delos Reyes.
During the pendency of the case, Delos Reyes sold the subject property to respondent siblings Anita, Angelina, Angelito and Amy (Burgos siblings). A new title was then issued in their names. The Burgos siblings, in turn, sold the same property to their aunt, Leonarda Burgos. However, the sale in favor of Leonarda was not registered. Thus, no title was issued in her name.
The subject property remained in the name of the Burgos siblings who also continued paying the real estate taxes thereon.
The trial court rendered its decision declaring that the Deed of Sale in favor of Delos Reyes was falsified as the signatures of the spouses Rufloe had
been forged. The trial court ruled that Delos Reyes did not acquire ownership over the subject property. Said decision had become final and executory. Respondents interposed an appeal to the CA. In their appeal, respondents maintained that they bought the property in good faith after they were shown a genuine copy of the title of the disputed property by Delos Reyes. They also insisted that they were innocent purchasers in good faith and for value. The CA reversed and set aside the ruling of the trial court, declaring in the process that respondents were purchasers in good faith and for value.
ISSUE:
(1) Whether the sale of the subject property by Delos Reyes to the Burgos siblings and the subsequent sale by the siblings to Leonarda were valid and binding; and (2) Whether respondents were innocent purchasers in good faith and for value despite the forged deed of sale of their transferor Delos Reyes.
RULING:
It is undisputed that the forged deed of sale was null and void and conveyed no title. It is a well-settled principle that no one can give what one does not have, nemo dat quod non habet. One can sell only what one owns or is authorized to sell, and the buyer can acquire no more right than what the seller can transfer legally. Due to the forged deed of sale, Delos Reyes acquired no right over the subject property which she could convey to the Burgos siblings. All the transactions subsequent to the falsified sale between the spouses Rufloe and Delos Reyes are likewise void, including the sale made by the Burgos siblings to their aunt, Leonarda.
As a general rule, every person dealing with registered land, as in this case, may safely rely on the correctness of the certificate of title issued therefor and will in no way oblige him to go beyond the certificate to determine the
condition of the property. However, this rule admits of an unchallenged exception: The circumstances surrounding this case point to the absolute lack of good faith on the part of respondents. The evidence shows that the Rufloes caused a notice of adverse claim to be annotated on the title of Delos Reyes and a action for damages and criminal case for estafa, filed by the Rufloes against Delos Reyes, were both pending before the court. This circumstance should have alerted the Burgos siblings as to the validity of Delos Reyes‘ title and her authority and legal right to sell the property.
Equally significant is the fact that Delos Reyes was not in possession of the subject property when she sold the same to the Burgos siblings. There was no showing that Amado or any of the Burgos siblings exerted any effort to personally verify with the Register of Deeds if Delos Reyes‘ certificate of title was clean and authentic. Although it is a recognized principle that a person dealing with registered land need not go beyond its certificate of title, it is also a firmly established rule that where circumstances exist which would put a purchaser on guard and prompt him to investigate further.
without such inquiry, the buyer can hardly be regarded as a buyer in good faith. Moreover, the defense of indefeasibility of a Torrens title does not extend to a transferee who takes it with notice of a flaw in the title of his transferor. To be effective, the inscription in the registry must have been made in good faith. A holder in bad faith of a certificate of title is not entitled to the protection of the law, for the law cannot be used as a shield for fraud.
Heirs of Spouses Joaquin Manguardia And Susana Manalo vs. Heirs of Simplicio Valles and Marta Valles G.R. No. 177616 August 27, 2014 FACTS:
Marta, Simplicio, Melquiades, Rustico, Visitacion and Catalina, all surnamed Valles, were siblings. Simplicio and Marta were the registered
owners of a 42,215-square meter property in Barrio Cudian, Ivisan, Capiz Juan, and Dominica, all surnamed Valles. With the exception of Felicisimo, all of Simplicio‘s children died single and childless. Felicisimo was survived by his wife, Presentacion Capapas, and his children Graciano, Sulpicio, Teresita and Antonio (now deceased).
On October 28, 1968, a notarized Deed of Absolute Sale over Lot 835 was executed by Simplicio and Marta in favor of their brothers, Melquiades and Rustico; Simplicio‘s daughter, Adelaida Valles (Adelaida); and Marta‘s daughter, Encarnacion. Said deed was registered in the Registry of Deeds of Capiz, resulting in the cancellation of OCT No. RO-4017 and the issuance of Transfer Certificate of Title (TCT) No.T-9409. the alleged buyers and new registered owners executed a Subdivision Agreement,12 subdividing Lot 835 into four lots. Said Subdivision Agreement was also registered on the same day in the Registry of Deeds of Capiz.
As a result of the conveyances, the registered owners of Lot 835 are:
a) Adelaida (Lot 835-A);
b) Spouses Manguardia (Lots 835-B and 835-C); and c) Leonardo and Rebecca (Lot 835-D).
On December 13, 1999, the heirs of Simplicio and Marta commenced an action for the Declaration of Nullity of Certificates of Title and Deeds of Sale, Cancellation of Certificates of Title, Recovery of Possession and Damages37 against the heirs of spouses Manguardia and the heirs of spouses Leonardo and Rebecca (petitioners) in the RTC of Roxas City.
Respondents alleged that in September 1998 they discovered the various documents of sale and titles covering Lot 835 when Teresita and her siblings agreed to subdivide the lot among the heirs of Simplicio and Marta and
searched for the title of the property in the Registry of Deeds of Capiz. They averred that the purported Deed of Absolute Sale dated October 28, 1968 is a forgery because Marta and Simplicio were long dead when the said document was executed. They averred that the purported Deed of Absolute Sale dated October 28, 1968 is a forgery because Marta and Simplicio were long dead when the said document was executed. Consequently, all titles emanating therefrom including the titles covering the subdivided lots of Lot 835 registered in the names of spouses Manguardia, Leonardo and Rebecca, and Adelaida, are all null and void. Respondents, therefore, prayed that petitioners be ordered to remove the improvements introduced on the disputed lot and vacate the same, and that a new title be issued over Lot 835 in the names of Marta and Simplicio as owners.
In their Answer, the heirs of spouses Manguardia averred that their predecessors-in-interest were innocent purchasers in good faith and for value, having acquired Lots 835-B and 835-C in 1980 from their registered owners and occupants, Pedro and Soledad. They further averred that their parents had been in possession of the lots since they purchased them in 1980, and had since then constructed four buildings thereon for their poultry business, without opposition from anyone, including Graciano who occupies the adjacent Lot 835-A. They maintained that the titles in the names of the spouses Manguardia are valid and legal. In addition, since the documents of sale and Torrens titles were duly registered in the Registry of Deeds, and that actual possession by the different transferees spanning a period of over 30 years were known to the respondents and their predecessors without any complaint or opposition, the claim of respondents is barred by prescription, estoppel and laches. The heirs of the spouses Manguardia moreover asserted that the Complaint against them fails to allege a cause of action and that the same was not brought by the real parties-in-interest.
ISSUE:
Whether the honorable court of appeals twentieth division erred in denying the appeal of petitioners and in affirming the assailed decision of the court a quo petitioners herein being buyers in good faith.
HELD:
The petition lacks merit.
Well entrenched is the principle that factual findings of the trial court, when adopted and confirmed by the CA, are final and conclusive and may not be reviewed on appeal by this Court. The Court‘s ―role in a petition under Rule 45 is limited to reviewing or reversing errors of law allegedly committed by the appellate court.‖ This rule, however, is not without well-defined exceptions. ―Findings of fact of the trial court and the CA may be set aside when such findings are not supported by the evidence or where the lower courts' conclusions are based on a misapprehension of facts.‖ Considering the contention of petitioners that misinterpretation of facts was committed, this Court embarked on the task of reviewing the facts of this case.