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GR No. 172961

2015-09-07

LEONEN, J.

The existence or non-existence of fraud is a legal conclusion based on a finding that the evidence presented is sufficient to establish facts constituting its elements.[1] Questions of fact are generally not entertained in a petition for review before this court.[2] In any event, petitions for a review or reopening of a decree of registration based on actual fraud must be filed before the proper court within the one-year period provided under the relevant laws.[3] The party alleging fraud must overcome the burden of proving the fraud with clear and convincing evidence.[4] Section 101 of Commonwealth No. 141 allows actions for the reversion of land fraudulently granted to private individuals filed even after the lapse of the one-year period,[5] but this must be initiated by the state.

GR No. 172961

2015-09-07

PEDRO MENDOZA v. REYNOSA VALTE

LEONEN, J.

The identity of the land in controversy involves a factual question. This requires a delineation of actual boundaries and a review of the admissibility and credibility of documents such as deeds of sale and survey plans.[87] The presence or absence of fraud also involves a factual question.[88]

GR No. 172961

2015-09-07

PEDRO MENDOZA v. REYNOSA VALTE

LEONEN, J.

Nonetheless, the burden of proving that respondent employed fraud in her free patent application falls on petitioners who made this assertion.[122] Petitioners failed to overcome this burden.

GR No. 172961

2015-09-07

PEDRO MENDOZA v. REYNOSA VALTE

LEONEN, J.

Different kinds of fraud exist, but the law allowing fraud as a ground for a review or reopening of a land registration decree contemplates actual and extrinsic fraud.[125]

GR No. 171804

2015-08-05

REGISTER OF DEEDS OF NEGROS OCCIDENTAL v. OSCAR ANGLO

LEONEN, J.

Every certificate of title contains an attestation that the person named is the owner of the property described in the certificate.[76] Hence, "every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and the law will in no way oblige him to go behind the certificate to determine the condition of the property."[77] When a certificate of title is clean and free from any encumbrance, potential purchasers have every right to rely on such certificate.[78] Individuals who rely on a clean certificate of title in making the decision to purchase the real property are often referred to as "innocent purchasers for value"[79] and "in good faith."[80]

GR No. 171804

2015-08-05

REGISTER OF DEEDS OF NEGROS OCCIDENTAL v. OSCAR ANGLO

LEONEN, J.

In addition, we need to depart from the rule in Treasurer of the Philippines and Spouses De Guzman, Jr. that the sale conveyed no interest to the buyer because the vendor did not have title. We emphasize that certificates of title, especially if in their original form and backed by the Register of Deeds, may be relied upon by purchasers.[102] Innocent purchasers should not be prejudiced by individuals who only appear to be owners but are not the actual owners. However, there should be complete compliance with the requirements of Section 95.

GR No. 171286

2014-06-02

DOLORES CAMPOS v. DOMINADOR ORTEGA

PERALTA, J.

The presence or absence of fraud is a factual issue.[16] As a general rule, only questions of law may be raised in a petition for review on certiorari filed with this Court and factual findings of the trial courts, when adopted and confirmed by the CA, are final and conclusive on this Court, except when the CA judgment is based on a misapprehension of facts or the factual inferences are manifestly incorrect or when that court overlooked certain relevant facts which, if properly considered, would justify a different conclusion.[17]

GR No. 175485

2011-07-27

CASIMIRO DEVELOPMENT CORPORATION v. RENATO L. MATEO

BERSAMIN, J.

There is no doubt that the land in question, although once a part of the public domain, has already been placed under the Torrens system of land registration. The Government is required under the Torrens system of registration to issue an official certificate of title to attest to the fact that the person named in the certificate is the owner of the property therein described, subject to such liens and encumbrances as thereon noted or what the law warrants or reserves. [11] The objective is to obviate possible conflicts of title by giving the public the right to rely upon the face of the Torrens certificate and to dispense, as a rule, with the necessity of inquiring further. The Torrens system gives the registered owner complete peace of mind, in order that he will be secured in his ownership as long as he has not voluntarily disposed of any right over the covered land. [12]

GR No. 170375

2010-07-07

REPUBLIC v. MAMINDIARA P. MANGOTARA

LEONARDO-DE CASTRO, J.

Reversion is an action where the ultimate relief sought is to revert the land back to the government under the Regalian doctrine. Considering that the land subject of the action originated from a grant by the government, its cancellation is a matter between the grantor and the grantee.[134] In Estate of the Late Jesus S. Yujuico v. Republic[135] (Yujuico case), reversion was defined as an action which seeks to restore public land fraudulently awarded and disposed of to private individuals or corporations to the mass of public domain. It bears to point out, though, that the Court also allowed the resort by the Government to actions for reversion to cancel titles that were void for reasons other than fraud, i.e., violation by the grantee of a patent of the conditions imposed by law;[136] and lack of jurisdiction of the Director of Lands to grant a patent covering inalienable forest land[137] or portion of a river, even when such grant was made through mere oversight.[138] In Republic v. Guerrero,[139] the Court gave a more general statement that the remedy of reversion can be availed of "only in cases of fraudulent or unlawful inclusion of the land in patents or certificates of title."

GR No. 161419

2009-08-25

EUGENIO ENCINARES v. DOMINGA ACHERO

NACHURA, J.

On this point, our ruling in Republic v. Guerrero,[37] is instructive: Fraud is of two kinds: actual or constructive. Actual or positive fraud proceeds from an intentional deception practiced by means of the misrepresentation or concealment of a material fact. Constructive fraud is construed as a fraud because of its detrimental effect upon public interests and public or private confidence, even though the act is not done with an actual design to commit positive fraud or injury upon other persons.

GR No. 167232

2009-07-31

D.B.T. MAR-BAY CONSTRUCTION v. RICAREDO PANES

NACHURA, J.

While the Torrens system is not a mode of acquiring title, but merely a system of registration of titles to lands, justice and equity demand that the titleholder should not be made to bear the unfavorable effect of the mistake or negligence of the State's agents, in the absence of proof of his complicity in a fraud or of manifest damage to third persons. The real purpose of the Torrens system is to quiet title to land and put a stop forever to any question as to the legality of the title, except claims that were noted in the certificate at the time of the registration or that may arise subsequent thereto. Otherwise, the integrity of the Torrens system would forever be sullied by the ineptitude and inefficiency of land registration officials, who are ordinarily presumed to have regularly performed their duties.[64] Thus, where innocent third persons, relying on the correctness of the certificate of title thus issued, acquire rights over the property, the court cannot disregard those rights and order the cancellation of the certificate. The effect of such outright cancellation will be to impair public confidence in the certificate of title. The sanctity of the Torrens system must be preserved; otherwise, everyone dealing with the property registered under the system will have to inquire in every instance on whether the title had been regularly or irregularly issued, contrary to the evident purpose of the law. Every person dealing with the registered land may safely rely on the correctness of the certificate of title issued therefor, and the law will in no way oblige him to go behind the certificate to determine the condition of the property.[65]

GR No. 177181

2009-07-07

RABAJA RANCH DEVELOPMENT CORPORATION v. AFP RETIREMENT

NACHURA, J.

Our ruling in Republic v. Guerrero,[32] is instructive:Fraud is of two kinds: actual or constructive. Actual or positive fraud proceeds from an intentional deception practiced by means of the misrepresentation or concealment of a material fact. Constructive fraud is construed as a fraud because of its detrimental effect upon public interests and public or private confidence, even though the act is not done with an actual design to commit positive fraud or injury upon other persons.

GR No. 175788

2009-06-30

ENRIQUITA ANGAT v. REPUBLIC

CHICO-NAZARIO, J.

Before Us is a Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court filed by petitioners Enriquita Angat (Enriquita) and the legal heirs of Federico Angat (Federico) against the respondent Republic of the Philippines (Republic), assailing the Decision[1] dated 5 December 2005 and Resolution[2] dated 4 December 2006 of the Court of Appeals in CA-G.R. CV No. 72740. In its assailed Decision, the Court of Appeals reversed the Order[3] dated 27 November 2000 of the Regional Trial Court (RTC), Branch XV, Naic, Cavite, in LRC Case No. 1331, which granted the Petition for Reconstitution of the original copy of Transfer Certificate of Title (TCT) No. T-4399 allegedly issued by the Register of Deeds of Cavite in the names of Federico[4] and Enriquita. The Court of Appeals denied petitioners' Motion for Reconsideration in its assailed Resolution dated 4 December 2006. Petitioners are also invoking in this Petition the power of this Court to issue a writ of certiorari under Rule 65 of the Revised Rules of Court, averring that the Court of Appeals acted without or in excess of jurisdiction or with grave abuse of discretion in dismissing the Petition for Reconstitution in LRC Case No. 1331.

GR No. 148846

2007-09-25

CECILIA AMODIA VDA. DE MELENCION v. CA

NACHURA, J.

Finally, 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 insure 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 losing his acquisition. 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.[59]

GR NO. 152518

2006-07-31

SPS. PRISCO P. CAL v. MARIANO A. ZOSA

SANDOVAL-GUTIERREZ, J.

Thus, relief is granted to a party deprived of his interest in land where the fraud consists in a deliberate misrepresentation that the lots are not contested when in fact, they are; or in willfully misrepresenting that there are no other claims; or in deliberately failing to notify the party entitled to notice; or in inducing him not to oppose an application; or in misrepresenting about the identity of the lot to the true owner by the applicant causing the former to withdraw his application. In all these examples, the overriding consideration is that the fraudulent scheme of the prevailing litigant prevented a party from having his day in court or from presenting his case. The fraud, therefore, is one that affects and goes into the jurisdiction of the court.[14]

	GR No. 172961 2015-09-07	PEDRO MENDOZA v. REYNOSA VALTE LEONEN, J.
The existence or non-existence of fraud is a legal conclusion based on a finding that the evidence presented is sufficient to establish facts constituting its elements.[1] Questions of fact are generally not entertained in a petition for review before this court.[2] In any event, petitions for a review or reopening of a decree of registration based on actual fraud must be filed before the proper court within the one-year period provided under the relevant laws.[3] The party alleging fraud must overcome the burden of proving the fraud with clear and convincing evidence.[4] Section 101 of Commonwealth No. 141 allows actions for the reversion of land fraudulently granted to private individuals filed even after the lapse of the one-year period,[5] but this must be initiated by the state.
	GR No. 172961 2015-09-07	PEDRO MENDOZA v. REYNOSA VALTE LEONEN, J.
The identity of the land in controversy involves a factual question. This requires a delineation of actual boundaries and a review of the admissibility and credibility of documents such as deeds of sale and survey plans.[87] The presence or absence of fraud also involves a factual question.[88]
	GR No. 172961 2015-09-07	PEDRO MENDOZA v. REYNOSA VALTE LEONEN, J.
Nonetheless, the burden of proving that respondent employed fraud in her free patent application falls on petitioners who made this assertion.[122] Petitioners failed to overcome this burden.
	GR No. 172961 2015-09-07	PEDRO MENDOZA v. REYNOSA VALTE LEONEN, J.
Different kinds of fraud exist, but the law allowing fraud as a ground for a review or reopening of a land registration decree contemplates actual and extrinsic fraud.[125]
	GR No. 171804 2015-08-05	REGISTER OF DEEDS OF NEGROS OCCIDENTAL v. OSCAR ANGLO LEONEN, J.
Every certificate of title contains an attestation that the person named is the owner of the property described in the certificate.[76] Hence, "every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and the law will in no way oblige him to go behind the certificate to determine the condition of the property."[77] When a certificate of title is clean and free from any encumbrance, potential purchasers have every right to rely on such certificate.[78] Individuals who rely on a clean certificate of title in making the decision to purchase the real property are often referred to as "innocent purchasers for value"[79] and "in good faith."[80]
	GR No. 171804 2015-08-05	REGISTER OF DEEDS OF NEGROS OCCIDENTAL v. OSCAR ANGLO LEONEN, J.
In addition, we need to depart from the rule in Treasurer of the Philippines and Spouses De Guzman, Jr. that the sale conveyed no interest to the buyer because the vendor did not have title. We emphasize that certificates of title, especially if in their original form and backed by the Register of Deeds, may be relied upon by purchasers.[102] Innocent purchasers should not be prejudiced by individuals who only appear to be owners but are not the actual owners. However, there should be complete compliance with the requirements of Section 95.
	GR No. 171286 2014-06-02	DOLORES CAMPOS v. DOMINADOR ORTEGA PERALTA, J.
The presence or absence of fraud is a factual issue.[16] As a general rule, only questions of law may be raised in a petition for review on certiorari filed with this Court and factual findings of the trial courts, when adopted and confirmed by the CA, are final and conclusive on this Court, except when the CA judgment is based on a misapprehension of facts or the factual inferences are manifestly incorrect or when that court overlooked certain relevant facts which, if properly considered, would justify a different conclusion.[17]
	GR No. 175485 2011-07-27	CASIMIRO DEVELOPMENT CORPORATION v. RENATO L. MATEO BERSAMIN, J.
There is no doubt that the land in question, although once a part of the public domain, has already been placed under the Torrens system of land registration. The Government is required under the Torrens system of registration to issue an official certificate of title to attest to the fact that the person named in the certificate is the owner of the property therein described, subject to such liens and encumbrances as thereon noted or what the law warrants or reserves. [11] The objective is to obviate possible conflicts of title by giving the public the right to rely upon the face of the Torrens certificate and to dispense, as a rule, with the necessity of inquiring further. The Torrens system gives the registered owner complete peace of mind, in order that he will be secured in his ownership as long as he has not voluntarily disposed of any right over the covered land. [12]
	GR No. 170375 2010-07-07	REPUBLIC v. MAMINDIARA P. MANGOTARA LEONARDO-DE CASTRO, J.
Reversion is an action where the ultimate relief sought is to revert the land back to the government under the Regalian doctrine. Considering that the land subject of the action originated from a grant by the government, its cancellation is a matter between the grantor and the grantee.[134] In Estate of the Late Jesus S. Yujuico v. Republic[135] (Yujuico case), reversion was defined as an action which seeks to restore public land fraudulently awarded and disposed of to private individuals or corporations to the mass of public domain. It bears to point out, though, that the Court also allowed the resort by the Government to actions for reversion to cancel titles that were void for reasons other than fraud, i.e., violation by the grantee of a patent of the conditions imposed by law;[136] and lack of jurisdiction of the Director of Lands to grant a patent covering inalienable forest land[137] or portion of a river, even when such grant was made through mere oversight.[138] In Republic v. Guerrero,[139] the Court gave a more general statement that the remedy of reversion can be availed of "only in cases of fraudulent or unlawful inclusion of the land in patents or certificates of title."
	GR No. 161419 2009-08-25	EUGENIO ENCINARES v. DOMINGA ACHERO NACHURA, J.
On this point, our ruling in Republic v. Guerrero,[37] is instructive: Fraud is of two kinds: actual or constructive. Actual or positive fraud proceeds from an intentional deception practiced by means of the misrepresentation or concealment of a material fact. Constructive fraud is construed as a fraud because of its detrimental effect upon public interests and public or private confidence, even though the act is not done with an actual design to commit positive fraud or injury upon other persons.
	GR No. 167232 2009-07-31	D.B.T. MAR-BAY CONSTRUCTION v. RICAREDO PANES NACHURA, J.
While the Torrens system is not a mode of acquiring title, but merely a system of registration of titles to lands, justice and equity demand that the titleholder should not be made to bear the unfavorable effect of the mistake or negligence of the State's agents, in the absence of proof of his complicity in a fraud or of manifest damage to third persons. The real purpose of the Torrens system is to quiet title to land and put a stop forever to any question as to the legality of the title, except claims that were noted in the certificate at the time of the registration or that may arise subsequent thereto. Otherwise, the integrity of the Torrens system would forever be sullied by the ineptitude and inefficiency of land registration officials, who are ordinarily presumed to have regularly performed their duties.[64] Thus, where innocent third persons, relying on the correctness of the certificate of title thus issued, acquire rights over the property, the court cannot disregard those rights and order the cancellation of the certificate. The effect of such outright cancellation will be to impair public confidence in the certificate of title. The sanctity of the Torrens system must be preserved; otherwise, everyone dealing with the property registered under the system will have to inquire in every instance on whether the title had been regularly or irregularly issued, contrary to the evident purpose of the law. Every person dealing with the registered land may safely rely on the correctness of the certificate of title issued therefor, and the law will in no way oblige him to go behind the certificate to determine the condition of the property.[65]
	GR No. 177181 2009-07-07	RABAJA RANCH DEVELOPMENT CORPORATION v. AFP RETIREMENT NACHURA, J.
Our ruling in Republic v. Guerrero,[32] is instructive:Fraud is of two kinds: actual or constructive. Actual or positive fraud proceeds from an intentional deception practiced by means of the misrepresentation or concealment of a material fact. Constructive fraud is construed as a fraud because of its detrimental effect upon public interests and public or private confidence, even though the act is not done with an actual design to commit positive fraud or injury upon other persons.
	GR No. 175788 2009-06-30	ENRIQUITA ANGAT v. REPUBLIC CHICO-NAZARIO, J.
Before Us is a Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court filed by petitioners Enriquita Angat (Enriquita) and the legal heirs of Federico Angat (Federico) against the respondent Republic of the Philippines (Republic), assailing the Decision[1] dated 5 December 2005 and Resolution[2] dated 4 December 2006 of the Court of Appeals in CA-G.R. CV No. 72740. In its assailed Decision, the Court of Appeals reversed the Order[3] dated 27 November 2000 of the Regional Trial Court (RTC), Branch XV, Naic, Cavite, in LRC Case No. 1331, which granted the Petition for Reconstitution of the original copy of Transfer Certificate of Title (TCT) No. T-4399 allegedly issued by the Register of Deeds of Cavite in the names of Federico[4] and Enriquita. The Court of Appeals denied petitioners' Motion for Reconsideration in its assailed Resolution dated 4 December 2006. Petitioners are also invoking in this Petition the power of this Court to issue a writ of certiorari under Rule 65 of the Revised Rules of Court, averring that the Court of Appeals acted without or in excess of jurisdiction or with grave abuse of discretion in dismissing the Petition for Reconstitution in LRC Case No. 1331.
	GR No. 148846 2007-09-25	CECILIA AMODIA VDA. DE MELENCION v. CA NACHURA, J.
Finally, 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 insure 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 losing his acquisition. 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.[59]
	GR NO. 152518 2006-07-31	SPS. PRISCO P. CAL v. MARIANO A. ZOSA SANDOVAL-GUTIERREZ, J.
Thus, relief is granted to a party deprived of his interest in land where the fraud consists in a deliberate misrepresentation that the lots are not contested when in fact, they are; or in willfully misrepresenting that there are no other claims; or in deliberately failing to notify the party entitled to notice; or in inducing him not to oppose an application; or in misrepresenting about the identity of the lot to the true owner by the applicant causing the former to withdraw his application. In all these examples, the overriding consideration is that the fraudulent scheme of the prevailing litigant prevented a party from having his day in court or from presenting his case. The fraud, therefore, is one that affects and goes into the jurisdiction of the court.[14]

REPUBLIC v. BENJAMIN GUERRERO