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VOLUNTAD v. SPS. MAGTANGGOL AND CORAZON DIZON

This case has been cited 3 times or more.

2009-08-25
NACHURA, J.
In the case at bar, the Belarminos were fully aware that the property was registered not in the name of the immediate transferor, Virgilio, but remained in the name of Pedro San Agustin and Agatona Genil.[42]  This fact alone is sufficient impetus to make further inquiry and, thus, negate their claim that they are purchasers for value in good faith.[43] They knew that the property was still subject of partition proceedings before the trial court, and that the compromise agreement signed by the heirs was not approved by the RTC following the opposition of the counsel for Eufemia and her six other co-heirs.[44]  The Belarminos, being transferees pendente lite, are deemed buyers in mala fide, and they stand exactly in the shoes of the transferor and are bound by any judgment or decree which may be rendered for or against the transferor.[45] Furthermore, had they verified the status of the property by asking the neighboring residents, they would have been able to talk to the Pahuds who occupy an adjoining business establishment[46] and would have known that a portion of the property had already been sold.  All these existing and readily verifiable facts are sufficient to suggest that the Belarminos knew that they were buying the property at their own risk.
2005-12-09
PANGANIBAN, J.
When dealing with land that is registered and titled, as in this case, buyers are not required by the law to inquire further than what the Torrens certificate of title indicates on its face.[28] It is also settled, however, that purchasers cannot close their eyes to known facts that should put a reasonable person on guard. They cannot subsequently claim to have acted in good faith in the belief that there was no defect in the vendor's certificate of title.[29] Their mere refusal to face up to that possibility will not make them innocent purchasers for value, if it later becomes clear that the title was indeed defective, and that they would have discovered the fact, had they acted with the measure of precaution required of a prudent person in a like situation.[30]