This case has been cited 25 times or more.
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2014-09-29 |
REYES, J. |
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| The rule, however, is not without recognized exceptions. "The conveyance shall not be valid against any person unless registered, except (1) the grantor, (2) his heirs and devisees, and (3) third persons having actual notice or knowledge thereof."[25] Moreover, "when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation,[26] he cannot find solace in the protection afforded by a prior registration. Neither can such person be considered an innocent purchaser for value nor a purchaser in good faith.[27] | |||||
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2014-09-17 |
VELASCO JR., J. |
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| [A] person dealing with registered land has a right to rely on the Torrens certificate of title and to dispense with the need of inquiring further except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor appearing on the face of said certificate. One who falls within the exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith and, hence, does not merit the protection of the law.[19] (emphasis added) | |||||
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2014-04-21 |
MENDOZA, J. |
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| According to the Saberons, the CA likewise erred in ruling that there was no constructive notice of the levy made upon the subject lands. They claimed that the appellate court could not solely rely on AFP Mutual Benefit Association Inc. v. Santiago.[5] Instead, they urged the Court to interpret Sections 52 and 42 of Presidential Decree (P.D.) No. 1529 which cover the effects of registration and the manner thereof; and to examine Section 54 which shows that, in addition to the filing of the instrument creating, transferring or claiming interest in registered land less than ownership, a brief memorandum of such shall be made by the Register of Deeds on the certificate of title and signed by him. Hence, the ruling in AFP, that an entry of a notice of levy and attachment in the primary entry or day book of the Registry of Deeds was sufficient notice to all persons that the land was already subject to such attachment, would be rendered as a superfluity in light of the mandatory character of the said provision. | |||||
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2012-08-15 |
BERSAMIN, J. |
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| First of all, a fundamental principle in land registration under the Torrens system is that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein.[12] The certificate of title thus becomes the best proof of ownership of a parcel of land;[13] hence, anyone who deals with property registered under the Torrens system may rely on the title and need not go beyond the title.[14] This reliance on the certificate of title rests on the doctrine of indefeasibility of the land title, which has long been well-settled in this jurisdiction. It is only when the acquisition of the title is attended with fraud or bad faith that the doctrine of indefeasibility finds no application.[15] | |||||
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2011-10-19 |
VILLARAMA, JR., J. |
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| In the case of Sandoval v. Court of Appeals,[38] the Court defined an innocent purchaser for value as one who buys property of another, without notice that some other person has a right to, or interest in, such property and pays a full and fair price for the same, at the time of such purchase, or before he has notice of the claim or interest of some other persons in the property. He is one who buys the property with the belief that the person from whom he receives the thing was the owner and could convey title to the property. A purchaser can not close his eyes to facts which should put a reasonable man on his guard and still claim that he acted in good faith. | |||||
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2011-07-27 |
BERSAMIN, J. |
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| To start with, one who deals with property registered under the Torrens system need not go beyond the certificate of title, but only has to rely on the certificate of title. [21] He is charged with notice only of such burdens and claims as are annotated on the title. [22] The pertinent law on the matter of burdens and claims is Section 44 of the Property Registration Decree, [23] which provides: Section 44.Statutory liens affecting title. -- Every registered owner receiving a certificate of title in pursuance of a decree of registration, and every subsequent purchaser of registered land taking a certificate of title for value and in good faith, shall hold the same free from all encumbrances except those noted on said certificate and any of the following encumbrances which may be subsisting, namely: | |||||
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2011-07-05 |
VELASCO JR., J. |
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| It is settled doctrine that one who deals with property registered under the Torrens system need not go beyond the four corners of, but can rely on what appears on, the title. He is charged with notice only of such burdens and claims as are annotated on the title. This principle admits of certain exceptions, such as when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry, or when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation. [146] A higher level of care and diligence is of course expected from banks, their business being impressed with public interest. [147] | |||||
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2010-11-22 |
LEONARDO-DE CASTRO, J. |
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| Indeed, the presence of anything which excites or arouses suspicion should prompt the vendee or mortgagee to look beyond the certificate and investigate the title of the vendor appearing on the face of said certificate.[10] If the vendee or mortgagee failed to do so before the execution of the contract, the vendee or mortgagee is deemed to be in bad faith and therefore cannot acquire any title under the forged instrument. | |||||
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2010-06-29 |
VELASCO JR., J. |
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| The general rule is that one dealing with a parcel of land registered under the Torrens System may safely rely on the correctness of the certificate of title issued therefor and is not obliged to go beyond the certificate.[41] Where, in other words, the certificate of title is in the name of the seller, the innocent purchaser for value has the right to rely on what appears on the certificate, as he is charged with notice only of burdens or claims on the res as noted in the certificate. Another formulation of the rule is that (a) in the absence of anything to arouse suspicion or (b) except where the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or (c) when the purchaser has knowledge of a defect of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property,[42] said purchaser is without obligation to look beyond the certificate and investigate the title of the seller. | |||||
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2009-04-24 |
TINGA, J. |
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| The result in the present case would still be the same even if the parties executed the mortgage deed after the Register of Deeds had cancelled the notice of lis pendens. It is true that one who deals with property registered under the Torrens system need not go beyond the same, but only has to rely on the face of the title. He is charged with notice only of such burdens and claims as are annotated on the title. However, this principle does not apply when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser or mortgagee has knowledge of a defect or the lack of title in his vendor or mortgagor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation. One who falls within the exception can neither be denominated an innocent purchaser or mortgagee for value nor a purchaser or mortgagee in good faith.[27] In the present case, the fact that the orders dismissing the case and directing the cancellation of the notice of lis pendens was not yet final and executory should have impelled the Cunanans to be wary of further developments, as in fact plaintiff filed a motion for reconsideration and the RTC granted the same. In short, the Cunanans' knowledge of the existence of a pending litigation involving the disputed property makes them mortgagees in bad faith. Hence, respondent could still recover the property from the Cunanans. | |||||
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2009-01-30 |
LEONARDO-DE CASTRO, J. |
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| ... a person dealing with registered land has a right to rely on the Torrens certificate of title and to dispense with the need of inquiring further except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor appearing on the face of said certificate. One who falls within the exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith and, hence, does not merit the protection of the law.[17] | |||||
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2008-12-18 |
TINGA, J. |
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| Sec. 19. If the certificate of title considered lost or destroyed, and subsequently found or recovered, is not in the name of the same person in whose favor the reconstituted certificate of title has been issued, the Register of Deeds or the party concerned should bring the matter to the attention of the proper regional trial court, which, after due notice and hearing, shall order the cancellation of the reconstituted certificate of title and render, with respect to the memoranda of new liens and encumbrances, if any, made in the reconstituted certificate of title, after its reconstitution, such judgment as justice and equity may require: Provided, however, That if the reconstituted certificate of title has been cancelled by virtue of any deed or instrument, whether voluntary or involuntary, or by an order of the court, and a new certificate of title has been issued, the procedure prescribed above, with respect to the memorandum of new liens and encumbrances made on the reconstituted certificate of title, after its reconstitution, shall be followed with respect to the new certificate of title, and to such new liens and encumbrances, if any, as may have been on the latter, after the issuance thereof.[42] | |||||
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2008-07-31 |
NACHURA, J. |
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| The Court notes that the Suntay ruling is based on Republic of the Philippines v. Court of Appeals,[11] decided in 1996 also through the pen of Justice Vicente V. Mendoza. In that case, the Court emphasized that the jurisdiction of the SAC is original and exclusive, not appellate. Republic, however, was decided at a time when Rule XIII, Section 11 was not yet present in the DARAB Rules. Further, Republic did not discuss whether the petition filed therein for the fixing of just compensation was filed out of time or not. The Court merely decided the issue of whether cases involving just compensation should first be appealed to the DARAB before the landowner can resort to the SAC under Section 57 of R.A. No. 6657. | |||||
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2008-07-04 |
NACHURA, J. |
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| Indeed, the general rule is that a purchaser may rely on what appears on the face of a certificate of title. He may be considered a purchaser in good faith even if he simply examines the latest certificate of title. An exception to this rule is when there exist important facts that would create suspicion in an otherwise reasonable man (and spur him) to go beyond the present title and to investigate those that preceded it.[34] The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor as appearing on the face of said certificate. One who falls within the exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith, hence, does not merit the protection of the law.[35] | |||||
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2007-03-28 |
CHICO-NAZARIO, J. |
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| The forged TCTs No. 200629 and 200630 were later administratively reconstituted, and although an investigation would show that their reconstitution was also attended with irregularities, TCTs No. RT-23687 (200629) and RT-23688 (200630) appear, on either face, to have been duly approved by the LRA and issued by the Quezon City Register of Deeds. With the cancellation of the reconstituted TCTs and the issuance of new ones, TCTs No. 30829, 30830, 30831, and 30832, in the name of BPC, any trace of forgery or irregularity as to BPC's titles was eliminated. TCTs No. 30829, 30830, 30831, and 30832 were clean, at least, until the annotation therein of the notice of lis pendens of the Republic on 21 October 1992. It is a settled doctrine that one who deals with property registered under the Torrens system need not go beyond the same, but only has to rely on the certificates of title. He is charged with notice only of such burdens and claims as are annotated on the certificates.[66] Herein intervenors, Nicolas-Agbulos and Abesamis, before purchasing subdivision lots in Parthenon Hills, looked into the TCTs of BPC and found nothing on the face thereof to raise doubts or suspicions as to their validity and authenticity. Besides, BPC was the holder of licenses and permits to subdivide, develop, and sell the subject lots as Parthenon Hills, issued by the appropriate government agencies, primarily HLURB. | |||||
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2007-03-28 |
CHICO-NAZARIO, J. |
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| According to Section 103 of the Land Registration Decree, whenever public lands is by the Government alienated, granted, or conveyed to any person, the same shall be brought under the operation of the said Decree and shall be deemed to registered lands to all intents and purposes under the Decree. And a well-settled doctrine in Our jurisdiction provides that one who deals with property registered under the Torrens system need not go beyond the same, but only has to rely on the title. He is charged with notice only of such burdens and claims as are annotated on the title.[31] The Mendozas' certificates of title were clean and, thus, MENCA Corporation, Jacinto Velez, Jr. and Carmen Velez-Ting were induced to acquire the same from the Mendozas. That they did so in good faith and for value was not even questioned herein. Their titles, rights, and interests to the fishpond area must be respected and protected. | |||||
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2006-03-28 |
GARCIA, J. |
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| It is worth stressing that the Torrens system was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized. If a person purchases a piece of land on the assurance that the seller's title thereto is valid, he should not run the risk of being told later that his acquisition was ineffectual after all. This would not only be unfair to him. What is worse is that if this were permitted, public confidence in the system would be eroded and land transactions would have to be attended by complicated and not necessarily conclusive investigations and proof of ownership. The further consequence would be that land conflicts could be even more abrasive, if not even violent. The government, recognizing the worthy purposes of the Torrens system, should be the first to accept the validity of titles issued thereunder once the conditions laid down by the law are satisfied.[34] | |||||
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2005-12-14 |
TINGA, J. |
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| Time and again, we have upheld the fundamental principle in land registration that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein.[30] It becomes the best proof of ownership of a parcel of land.[31] One who deals with property registered under the Torrens system may rely on the title and need not go beyond the same.[32] Such principle of indefeasibility has long been well-settled in this jurisdiction and it is only when the acquisition of the title is attended with fraud or bad faith that the doctrine finds no application.[33] | |||||
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2005-12-09 |
PANGANIBAN, J. |
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| Thus, the presence of anything that excites or arouses suspicion should then prompt the vendee to look beyond the vendor's certificate and investigate the title appearing on the face of that certificate.[31] A vendee who does not do so cannot be denominated either as an innocent purchaser for value or as a purchaser in good faith and, hence, does not merit the protection of the law. | |||||
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2005-08-30 |
CARPIO, J. |
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| The trial and appellate courts pointed out that as early as 1966, there was already a brewing dispute between respondents and Luis over Lot 2. Luis conveyed Lot 2-A, one of the subdivided portions of Lot 2, to Napoleon on 28 December 1967. Maria, Napoleon's widow, testified that she was with Napoleon when Luis sold to them Lot 2-A.[12] Maria asserted that she was familiar with the history of Lot 2-A and the supposed previous owners, Luis and Felomina.[13] It was thus impossible for Napoleon and Maria not to have known of the Bureau of Lands' pending investigation and the incarceration of Segunda and Valentino at the time Luis sold to them Lot 2-A. The controversy between respondents and Luis should have prompted Napoleon to inquire into the status of Luis' title over Lot 2-A. A purchaser cannot close his eyes to facts that should put a reasonable man on his guard and still claim that he acted in good faith.[14] A holder in bad faith of a certificate of title is not entitled to the protection of the law. | |||||
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2005-08-18 |
AUSTRIA-MARTINEZ, J. |
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| The binding effect of the CA's factual findings on this Court applies with greater force when both the trial court and the CA are in complete agreement on their factual findings.[22] It is also settled that absent any circumstance requiring the overturning of the factual conclusion made by the trial court, particularly if affirmed by the CA, the Court necessarily upholds such findings of fact.[23] | |||||
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2003-08-28 |
YNARES-SANTIAGO, J. |
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| The necessity to strike down the contract of July 5, 1963 as a whole, not merely as to the share of the wife, is not without its basis in the common-sense rule. To be underscored here is that upon the provisions of Articles 161, 162 and 163 of the Civil Code, the conjugal partnership is liable for many obligations while the conjugal partnership exists. Not only that. The conjugal property is even subject to the payment of debts contracted by either spouse before the marriage, as those for the payment of fines and indemnities imposed upon them after the responsibilities in Article 161 have been covered (Article 163, par. 3), if it turns out that the spouse who is bound thereby, "should have no exclusive property or if it should be insufficient." These are considerations that go beyond the mere equitable share of the wife in the property. These are reasons enough for the husband to be stopped from disposing of the conjugal property without the consent of the wife. Even more fundamental is the fact that the nullity is decreed by the Code not on the basis of prejudice but lack of consent of an indispensable party to the contract under Article 166.[37] With respect to the third issue, the Court finds that respondent spouses are not purchasers in good faith. A purchaser in good faith is one who buys property of another, without notice that some other person has a right to, or interest in, such property and pays full and fair price for the same, at the time of such purchase, or before he has notice of the claim or interest of some other persons in the property. He buys the property with the belief that the person from whom he receives the thing was the owner and could convey title to the property. A purchaser cannot close his eyes to facts which should put a reasonable man on his guard and still claim he acted in good faith.[38] | |||||
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2003-04-09 |
YNARES-SANTIAGO, J. |
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| It is true that one who deals with property registered under the Torrens system need not go beyond the same, but only has to rely on the title. He is charged with notice only of such burdens and claims as are annotated on the title. However, this principle does not apply when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation. One who falls within the exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith.[23] | |||||