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RENATO S. SANCHEZ v. RODOLFO M. QUINIO

This case has been cited 5 times or more.

2014-04-23
PERALTA, J.
Stretching petitioners' contention a bit further, granting that both petitioners and respondents bought the disputed lots in good faith by simply relying on the certificates of the sellers, and subsequently, acquiring titles in their own names, respondents' title shall still prevail. It is a settled rule that when two certificates of title are issued to different persons covering the same land in whole or in part, the earlier in date must prevail, and, in case of successive registrations where more than one certificate is issued over the land, the person holding a prior certificate is entitled to the land as against a person who relies on a subsequent certificate.[37]  The titles of respondents, having emanated from an older title, should thus be upheld.
2013-11-27
MENDOZA, J.
Where the owner, however, could not be charged with negligence in the keeping of its duplicate certificates of title or with any act which could have brought about the issuance of another title relied upon by the purchaser or mortgagee for value, then the innocent registered owner has a better right over the mortgagee in good faith.[43]  For "the law protects and prefers the lawful holder of registered title over the transferee of a vendor bereft of any transmissible rights."[44]
2010-10-13
The Court agrees with the Republic that necessarily, the rights to and interests in the entire 38.23 hectares, covered by OCT Nos. 0-1200 (a.f.) and 0-1201 (a.f.), claimed by Vidal as the declared sole heir of Doña Demetria in the Quieting of Title Case, should be without prejudice to the outcome of the Cancellation of Titles and Reversion Case yet to be heard by the RTC-Branch 4.  As Vidal's successor-in-interest to the 23 hectares of the subject properties, AZIMUTH only stepped into the former's shoes in so far as said portion is concerned. No one can acquire a right greater than what the transferor himself has.  As the saying goes, the spring cannot rise higher than its source.[5]  As a consequence, the rights to and interests in the 23-hectare portion of the subject properties, acquired by AZIMUTH under the 1998 Memorandum of Agreement and 2004 Deed of Conditional Conveyance, referred to by this Court in the Quieting of Title Case, are likewise dependent on the final judgment in the Cancellation of Titles and Reversion Case.
2010-03-15
CORONA, J.
Nonetheless, without undermining the reason behind this doctrine (of protecting innocent purchasers for value), we hold that petitioner is entitled to the property following Sanchez v. Quinio.[14] In Sanchez, a 300 sq. m. parcel of land, registered under the name of one Celia P. Santiago and covered by TCT No. 391688, was sold by Santiago herself to therein respondents Rodolfo M. Quinio and Ismael M. Quinio. Respondents thereafter duly registered the deed of sale resulting in the issuance of TCT No. S-89991, in their (Quinios') names, on July 13, 1979.
2006-09-26
CALLEJO, SR., J.
The claim of indefeasibility of the petitioner's title under the Torrens land title system would be correct if previous valid title to the same parcel of land did not exist. The respondent had a valid title x x x It never parted with it; it never handed or delivered to anyone its owner's duplicate of the transfer certificate of title; it could not be charged with negligence in the keeping of its duplicate certificate of title or with any act which could have brought about the issuance of another certificate upon which a purchaser in good faith and for value could rely. If the petitioner's contention as to indefeasibility of his title should be upheld, then registered owners without the least fault on their part could be divested of their title and deprived of their property. Such disastrous results which would shake and destroy the stability of land titles had not been foreseen by those who had endowed with indefeasibility land titles issued under the Torrens system.[26] Remegia's TCT No. T-8502, thus, prevails over respondent Aurelio's TCT No. 17793, especially considering that, as earlier opined, the latter was correctly nullified by the RTC as it emanated from the new owner's duplicate TCT No. T-8502, which in turn, respondent Aurelio was able to procure through fraudulent means.