MATEO CARIÑO vs THE INSULAR GOVERNMENT

FACTS:
On June 23, 1903, Mateo Cariňo went to the Court of Land Registration to petition his
inscription as the owner of a 146 hectare land he’s been possessing in the then
municipality of Baguio. Mateo only presented possessory information and no other
documentation. The State opposed the petition averring that the land is part of the US
military reservation. The CLR ruled in favor of Mateo. The State appealed. Mateo lost.
Mateo averred that a grant should be given to him by reason of immemorial use and
occupation as in the previous case Cansino vs Valdez & Tiglao vs Government.

ISSUE: Whether or not Mateo is the rightful owner of the land by virtue of his possession
of it for some time.

HELD: No. The statute of limitations did not run against the government. The government
is still the absolute owner of the land (regalian doctrine). Further, Mateo’s possession of
the land has not been of such a character as to require the presumption of a grant. No
one has lived upon it for many years. It was never used for anything but pasturage of
animals, except insignificant portions thereof, and since the insurrection against Spain it
has apparently not been used by the petitioner for any purpose.

While the State has always recognized the right of the occupant to a deed if he proves
a possession for a sufficient length of time, yet it has always insisted that he must
make that proof before the proper administrative officers, and obtain from them
his deed, and until he did the State remained the absolute owner. Land was not
registered, and therefore became, if it was not always, public land.

Spanish Law: "Where such possessors shall not be able to produce title
deeds, it shall be sufficient if they shall show that ancient possession, as a valid
title by prescription." For cultivated land, 20 years, uninterrupted, is enough. For
uncultivated, 30.

Applicant's possession was not unlawful, and no attempt at any such

proceedings against him or his father ever was made.

Every native who had not a paper title is not a trespasser.

There must be a presumption against the government when a private

individual claims property as his or her own. It went so far as to say that the lands
will be deemed private absent contrary proof.

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Legarda vs Saleeby,

Facts: A stone wall stands between the adjoining lot of Legarda and Saleeby. The said wall
and the strip of land where it stands is registered in the Torrens system under the name
of Legarda in 1906. Six years after the decree of registration is released in favor of
Legarda, Saleeby applied for registration of his lot under the Torrens system in 1912, and
the decree issued in favor of the latter included the stone wall and the strip of land where
it stands.
Issue: Who should be the owner of a land and its improvement which has been registered
under the name of two persons?
Held: For the issue involved, The Land Registration Act (Act 496) affords no remedy.
However, it can be construed that where two certificates purports to include the same
registered land, the holder of the earlier one continues to hold title and will prevail.
The real purpose of the Torrens system of registration, is to quiet title to land; to put a
stop forever to any question of the legality of the title, except claims which were noted
at the time of registration, in the certificate, or which may arise subsequent thereto. That
being the purpose of the law, once a title is registered the owner may rest secure, without
the necessity of waiting in the portals of the court, or sitting in the “mirador de su casa,”
to avoid the possibility of losing his land.
The law guarantees the title of the registered owner once it has entered into the Torrens
system.
Ratio: One ruling exposes all persons purchasing or dealing in registered lands to
unknown, unspecified and uncertain dangers, to guard against which all such persons will
be put to additional cost, annoyance and labor on every occasion when any transaction is
had with regard to such lands; while the other ruling tends to eliminate consequences so
directly adverse to the purpose and object for which the land registration law was
enacted, and imposes no burden upon any holder of a certificate of registered lands other
than that of defending his title on those rare, definite and specific occasions wherein he
has actual notice that his title is being challenged in a Court of Land Registration, a
proceeding in which the cost and expense is reduced to the minimum by the conclusive
character of his certificate of title in support of his claim of ownership. Furthermore,
judgment against the innocent purchaser and in favor of the holder of the earlier
certificate in a case such as that under consideration must inevitably tend to increase the
danger of double or overlapping registrations by encouraging holders of registered titles,
negligently or fraudulently and conclusively, to permit default judgments to be entered
against them adjudicating title to all or a part of their registered lands in favor of other
applicants, despite actual notice of the pendency of judicial proceedings had for that
purpose, and this, without adding in any appreciable degree to the security of thir titles,
and merely to save them the very slight trouble or inconvenience incident to an entry of
appearance in the court in which their own titles were secured, and inviting attention to
the fact that their right, title and ownership in the lands in questions has already been
conclusively adjudicated.

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REPUBLIC OF THE PHILIPPINES, represented by the MINDANAO MEDICAL CENTER,
petioner,
vs.
HON. COURT OF APPEALS and ALEJANDRO Y DE JESUS, respondents.

On January 22, 1921, Eugenio de Jesus, the father of respondent Alejandro de Jesus,
applied with the Bureau of Lands for Sales Patent (Sales Application No. 5436) of a 33-
hectare situated in barrio Libaron, Municipality of Davao (now Davao City). 1 The property
applied for was a portion of what was then known as Lot 522 of the Davao Cadastre.
On January 23, 1934, the Bureau of Lands, through its Davao District Land Officer,
accepted sealed bids for the purchase of the subject land. One Irineo Jose bidded for
P20.00 per hectare, while a certain Dr. Josc Ebro submitted a bid of P100.50 per hectare
The Director of Lands, however, annulled the auction sale for the reason that the sales
applicant, Eugenio de Jesus, failed to participate in the bidding for non-service of notice
on him of the scheduled bidding.
In lieu of that sale, another bidding was held on October 4, 1934. Sales applicant Eugenio
de Jesus was the lone bidder. He equalled the bid previously submitted by Dr. Jose Ebro
and made a deposit of P221.00 representing 10% of the price of the land at P100.50 per
hectare.
On November 23, 1934, the Director of Lands issued to Eugenio de Jesus an Order of
Award, the dispositive portion of which reads: ñé+.£ªwph!1
In view of the foregoing, and it appearing that the proceedings had in connection with
the Sales Application No. 5436 were in accordance with law and existing regulations, the
land covered thereby is herebyawarded to the said applicant, Eugenio de jesus, at P100.50
per hectare or P2,211.00 for the whole tract.
Because the area conveyed had not been actually surveyed at the time Eugenio de Jesus
filed his Sales Application, the Bureau of Lands conducted a survey under Plan Bsd-1514.
On July 29, 1936, the plan was approved and the land awarded to Eugenio de Jesus was
designated as Lot Nos. 1176-A, 1176-B-1-A and 1176-B-1-B with an aggregate area of
20.6400 hectares, Bsd-10153, City of Davao.
On August 28, 1936, the Director of Lands ordered an amendment of the Sales Application
of Eugenio de Jesus stating that "a portion of the land covered by Sales Application No.
5436 (E-3231) of Eugenio de Jesus is needed by the Philippine Army for military camp site
purposes, the said application is amended so as to exclude therefrom portion "A" as
shown in the sketch on the back thereof, and as thus amended, it will continue to be given
due course." The area excluded was Identified as Lot 1176-B-2, the very land in question,
consisting of 12.8081 hectares.
On September 7, 1936, President Manuel L. Quezon issued Proclaimation No. 85
withdrawing Lot No. 1176-B-2 from sale and settlement and reserving the same for
military purposes, under the administration of the Chief of Staff, Philippine Army.
On November 29, 1939, Eugenio de Jesus paid P660.45 covering the 8th and 10th
installment for 20.6400 hectares, the remaining area after his Sales Application was
amended. This payment did not include the military camp site (Lot No. 1176-B-2) as the

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same had already been excluded from the Sales Application at the time the payment was
made. Thereafter, or on May 15, 1948, then Director of Lands Jose P. Dans ordered the
issuance of patent to Eugenio de Jesus, pursuant to his Sales Application for "a tract of
land having an area of 20.6400 hectares, situated in the barrio of Poblacion, City of Davao.
On the same date, then Secretary of Agriculture and Natural Resources Mariano
Garchitorena granted a Sales Patent to Eugenio de Jesus for "a tract of agricultural public
land situated in the City of Davao, Island of Mindanao, Philippines, containing an area of
20 hectares, 64 ares, and 00 centa.

ISSUE: Whether or not petitioner Mindanao Medical Center has registerable title over a
full 12.8081-hectare land by virtue of an executive proclamation in 1956 reserving the
area for medical center site purposes.

HELD: YES

RATIO: Even on the gratuitous assumption that a donation of the military "camp site" was
executed between Eugenior de jesus and Serafin Marabut, such donation would anyway
be void, because Eugenior de jesus held no dominical rights over the site when it was
allegedly donated by him in 1936. In that year, proclamation No. 85 of President Quezon
already withrew the area from sale or settlement and reserved it for military purposes.
Respondent Appellate Court, however, rationalizes that the subject of the donation was
not the land itself but "the possessory and special proprietary rights" of Eugenio de jesus
over it. We disagree. It is true that the gratiuitous disposal in donation may consist of a
thing or right. But the term "right" must be understood in a "propriety" sense, over which
the processor has the jus disponendi. This is because, in true donations, there results a
consequent impoverishment of the donor or diminution of his assets. Eugenio de Jesus
cannot be said to be possessed of that "proprietary " right over the whole 33 hectares in
1936 including the disputed 12.8081 hectares for at that time this 12.8081-hectare lot
had already been severed from the mass of disposable public lands by Proclamation No.
85 and excluded in the Sales Award. Impoverishment of Eugenio's assets as a
consequence of such donation is therefore farfetehed. In fact, even if We were to assume
in gratia argumenti that the 12.8081-hectare lot was included in the Sales Award, still the
same may not be the subject of donation.

Chavez v. Pea and Amari

Fact:
In 1973, the Comissioner on Public Highways entered into a contract to reclaim areas of
Manila Bay with the Construction and Development Corportion of the Philippines (CDCP).
PEA (Public Estates Authority) was created by President Marcos under P.D. 1084, tasked
with developing and leasing reclaimed lands. These lands were transferred to the care of
PEA under P.D. 1085 as part of the Manila Cavite Road and Reclamation Project (MCRRP).

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CDCP and PEA entered into an agreement that all future projects under the MCRRP would
be funded and owned by PEA.
By 1988, President Aquino issued Special Patent No. 3517 transferring lands to PEA. It was
followed by the transfer of three Titles (7309, 7311 and 7312) by the Register of Deeds of
Paranaque to PEA covering the three reclaimed islands known as the FREEDOM ISLANDS.
Subsquently, PEA entered into a joint venture agreement (JVA) with AMARI, a Thai-
Philippine corporation to develop the Freedom Islands. Along with another 250 hectares,
PEA and AMARI entered the JVA which would later transfer said lands to AMARI. This
caused a stir especially when Sen. Maceda assailed the agreement, claiming that such
lands were part of public domain (famously known as the “mother of all scams”).
Peitioner Frank J. Chavez filed case as a taxpayer praying for mandamus, a writ of
preliminary injunction and a TRO against the sale of reclaimed lands by PEA to AMARI and
from implementing the JVA. Following these events, under President Estrada’s admin,
PEA and AMARI entered into an Amended JVA and Mr. Chaves claim that the contract is
null and void.
Issue:
w/n: the transfer to AMARI lands reclaimed or to be reclaimed as part of the stipulations
in the (Amended) JVA between AMARI and PEA violate Sec. 3 Art. XII of the 1987
Constitution
w/n: the court is the proper forum for raising the issue of whether the amended joint
venture agreement is grossly disadvantageous to the government.
Held:
On the issue of Amended JVA as violating the constitution:
1. The 157.84 hectares of reclaimed lands comprising the Freedom Islands, now covered
by certificates of title in the name of PEA, are alienable lands of the public domain. PEA
may lease these lands to private corporations but may not sell or transfer ownership of
these lands to private corporations. PEA may only sell these lands to Philippine citizens,
subject to the ownership limitations in the 1987 Constitution and existing laws.
2. The 592.15 hectares of submerged areas of Manila Bay remain inalienable natural
resources of the public domain until classified as alienable or disposable lands open to
disposition and declared no longer needed for public service. The government can make
such classification and declaration only after PEA has reclaimed these submerged areas.
Only then can these lands qualify as agricultural lands of the public domain, which are the
only natural resources the government can alienate. In their present state, the 592.15
hectares of submerged areas are inalienable and outside the commerce of man.
3. Since the Amended JVA seeks to transfer to AMARI, a private corporation, ownership
of 77.34 hectares110 of the Freedom Islands, such transfer is void for being contrary to
Section 3, Article XII of the 1987 Constitution which prohibits private corporations from
acquiring any kind of alienable land of the public domain.
4. Since the Amended JVA also seeks to transfer to AMARI ownership of 290.156
hectares111 of still submerged areas of Manila Bay, such transfer is void for being
contrary to Section 2, Article XII of the 1987 Constitution which prohibits the alienation
of natural resources other than agricultural lands of the public domain.

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PEA may reclaim these submerged areas. Thereafter, the government can classify the
reclaimed lands as alienable or disposable, and further declare them no longer needed
for public service. Still, the transfer of such reclaimed alienable lands of the public domain
to AMARI will be void in view of Section 3, Article XII of the 1987Constitution which
prohibits private corporations from acquiring any kind of alienable land of the public
domain.

REPUBLIC vs. DOLDOL

FACTS:

Sometime in 1959, respondent Nicanor Doldol occupied a portion of land in Opol, Misamis
Oriental. On 1963, he filed an application for saltwork purposes for the said area but the
Director of Forestry rejected the same. Sometime in 1965, the Provincial Board of Misamis
Oriental passed a resolution reserving a certain lot as a school site. This lot unfortunately
included the lot of Doldol. Sometime in 1970, the Opol High School filed a complaint for
accion possessoria with the RTC, the court ruled on school’s power. On appeal, the CA
reversed the decision of teh court ruling that Doldol was entitledto the portion he
occupied, he having possessed the same for 32 years (1959-1991).

ISSUE: Whether or not Doldol has the better right to possess the land in dispute?

HELD: No. The Public Land Act requires that the applicant must prove (a) that the land is
alienable public land and (b) that his open, continuous, exclusive and notorious
possession and occupation of the same must either be since time immemorial or for the
period prescribed in the Public Land Act. When the conditions set by law are complied
with the possessor of the land, by operation of law, acquires a right to grant, a
government grant, without the necessity of title/certificate of tile being issued.

The evidence presented shows that the land in dispute is alienable and disposable
in accordance with the District Forester’s Certification. Doldol thus meets the first
requirement.

Consequently, Doldol could not have acquired an imperfect title to the disputed
land since his occupation of the same started only in 1955, much later than June 12, 1945.
Not having complied with the conditions set forth by law, Doldol cannot be said to have
acquired a right to the land or a right to assert a right superior to the school given that
then Pres. Aquino had reserved the lot for Opol National School.

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 “The privilege occupying public lands with a view of pre-empting confers no
contractual or vested right in the land occupied and the authority of the President to
withdraw such lands for sale or acquisition by the public, or to reserve them for public
use, prior to divesting by the government of title thereof stands eventhough this may
defeat the imperfect right of settler. Lands covered by reservation are not subject to
entry, and no lawful settlement on them can be acquired” (Solicitor General)

In sum, Opol National Schoolhas the better right of possession over the land in
dispute.

property.

Cruz vs Secretary of DENR

Natural Resources and Environmental Law; Constitutional Law; IPRA; Regalian Doctrine

GR. No. 135385, Dec. 6, 2000

FACTS: Petitioners Isagani Cruz and Cesar Europa filed a suit for prohibition and mandamus as
citizens and taxpayers, assailing the constitutionality of certain provisions of Republic Act No.
8371, otherwise known as the Indigenous People’s Rights Act of 1997 (IPRA) and its
implementing rules and regulations (IRR). The petitioners assail certain provisions of the IPRA
and its IRR on the ground that these amount to an unlawful deprivation of the State’s ownership
over lands of the public domain as well as minerals and other natural resources therein, in
violation of the regalian doctrine embodied in section 2, Article XII of the Constitution.

ISSUE: Do the provisions of IPRA contravene the Constitution?

HELD: No, the provisions of IPRA do not contravene the Constitution. Examining the IPRA, there
is nothing in the law that grants to the ICCs/IPs ownership over the natural resources within
their ancestral domain. Ownership over the natural resources in the ancestral domains remains
with the State and the rights granted by the IPRA to the ICCs/IPs over the natural resources in
their ancestral domains merely gives them, as owners and occupants of the land on which the
resources are found, the right to the small scale utilization of these resources, and at the same
time, a priority in their large scale development and exploitation.

Additionally, ancestral lands and ancestral domains are not part of the lands of the
public domain. They are private lands and belong to the ICCs/IPs by native title, which is a
concept of private land title that existed irrespective of any royal grant from the State. However,

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the right of ownership and possession by the ICCs/IPs of their ancestral domains is a limited
form of ownership and does not include the right to alienate the same.

Ignacio Grande et al. vs Court of Appeals Gr. No. L-17652 June 30, 1962

FACTS: Ignacio, Eulogia, Alfonso, Eulalia, and Sofia Grande inherited a parcel of land from their
parents wherein its northeastern boundary was the Cagayan River.

Through the actions of the river an accretion of around 1.9 hectares formed through alluvial
deposit.

Domingo and Esteban Calalung has then possessed said accretion since 1933, while Ignacio et al.
entered the land with a claim of ownership in 1948

In 1958 Ignacio et al. filed a petition to quiet title of the said portion of land claiming that they
have been in open, peaceful, notorious, and continuous possession of the land and their
predecessors-in-interest since prior 1933 when Domingo and Esteban claimed to have
possessed the land

The trial court ruled in favor of Ignacio et al. based on their title to the land wherein the
accretion was attached to and saying that lands covered by a title cannot be acquired by
another through prescription

The court of appeals reversed the decision of the trial court based on the two witnesses
produced by Domingo and Esteban and the Tax Declarations they have presented and saying
that the latter has indeed acquired through prescription the said land formed by alluvium

ISSUE: Who the land formed through accretion by alluvium?

HELD: Domingo and Esteban Calalung has acquired the land through prescription. Although the
provisions of the Civil Code provides that accretion formed by alluvium is part of the land of the
riparian owner whose land is situated adjacent to the river bank and thus has a claim of
ownership thereof, the Land Registration and Cadastral acts provide that imprescriptibility of a
land is only gained when a Torrens Title has been issued covering the said land, Registration
under the Land Registration and Cadastral Acts does not vest or give title to the land, but merely
confirms and thereafter protects the title already possessed by the owner, making it
imprescriptible by occupation of third parties. The petitioners, Ignacio et al, never sought for the
registration of the land formed by alluvium, thus said land has not acquired the shield from
acquisitive prescription. Land formed by alluvium must is owned by the riparian owner whose
land is adjacent to the river bank where the accretion has formed but must register the
accretion separately to acquire a Torrens Title over the same.

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Pugeda v. Trias

Doctrine: Upon the issuance of the certificate of sale to the husband of a lot of the Friar Lands,
said lot ipso facto forms part of the conjugal properties of the husband and wife and this status
remains unaltered even after his death and the subsequent transfer of the land in the name of
the widow or by the setting aside of the trial court's decision holding said property as conjugal
by the Court of Appeals based on newly discovered evidence.

Facts: Movants argued that, (1) the lots purchased by Miguel Trias under the operation of the
Friar Lands Act which at the time of his death were not yet fully paid and were subsequently

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transferred in the name of the widow who paid the balance out of the proceeds of the fruits of
said lands and thereafter the title was issued in her name, belong to her as her exclusive
paraphernal property not conjugal;

(2) that the decision of the trial court was set aside by the Court of Appeals; and

(3) that the lots were never partitioned as conjugal assets of spouses Mariano Trias and Maria C.
Ferrer. Movants cited the case of Arayata vs. Joya, et al., 51 Phil. 654. The Supreme Court denied
the motion and declared the decision as final.

Ruling:

Upon the issuance of the certificate of sale to the husband of a lot of the Friar Lands, said lot
ipso facto forms part of the conjugal properties of the husband and wife and this status remains
unaltered even after his death and the subsequent transfer of the land in the name of the
widow or by the setting aside of the trial court's decision holding said property as conjugal by
the Court of Appeals based on newly discovered evidence. The doctrine in the Arayata vs. Joya,
et al. case refers to the superior right of the widow recognized in Section 16 of Act 1120 (Friar
Lands Act) over transfers made by the husband without the approval of the Director of Lands;
hence, not applicable in the instant case. Adjudication may be made pro indiviso in a project of
partition without the need of actual division or partition of the properties among the heirs.

SOLID STATE MULTI-PRODUCTS CORPORATION vs. THE COURTOF APPEALS and THE
INTESTATE ESTATE OF ANTENOR S. VIRATAand the DBPG.R. No. 83383 May 6, 1991

FACTS: Petitioner, a domestic corporation, filed an action for quieting of title against the
respondent estate of Virata alleging that it is the registered owner of a parcel of land (a
friar land) located at Imus, Cavite, which was covered by a Certificate of Title issued on February
24, 1976;that Virata, during his lifetime thru the use of fraud, caused the issuance of Certificate
of Title on September 1, 1959 thru an administrative reconstitution of a nonexistent
original title covering the same parcel of land; that by reason of the said reconstitution and
subsequent issuance of TCT, there now exists a cloud on the title of petitioner. On the other
hand, respondent Virata denied the allegations in the complaint, contending that his
predecessor, one Mabini Legaspi, bought the subject property through a public bidding, wherein
consequently, a TCT was issued in his name, and that subsequently a deed of sale was executed
in favor of Virata. Such deed was then registered with the Register of Deeds, who later on
issued a TCT to Virata. However, the Provincial Capitol building of Cavite which housed the
Registry of Deeds was burned, destroying land records and titles in d registry among which were
the records relating to the subject property. Hence, the RD administratively
reconstituted the original TCT based on owner's duplicatecertificate.

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ISSUE: Whether petitioner’s contention is meritorious

HELD: Yes Sale of the subject land to Mabini Legaspi, respondent’s predecessor is void
o There was neither allegation nor proof that the sale was with the approval of the Secretary of
Agriculture and Commerce. The absence of such approval made the supposed sale null and void
ab initio.

o Without the certificate of sale to prove the transfer of the ownership of the land from
the government Mabini Legaspi and without the required approval of the sale by the
Secretary of Agriculture and Commerce, he did not in any manner acquire ownership
over the land in 1943.

o The ownership or title over the subject land remained in the government until Peñaranda,
petitionerspredecessor, lawfully acquired ownership over thesame lot on February 28, 1969
by virtue of a salescontract executed in his favor. The issuance of a certificate of title in favor of
Mabini Legaspidid not vest ownership upon respondent over the land nor did itvalidate the
alleged purchase of the lot, which is null and void.Time and again, it has been held that
registration does not vesttitle. It is merely evidence of such title over a
particularproperty. Our land registration laws do not give the holder anybetter title than that
what he actually has Did petitioner’s action prescribe? NO

o Although a period of one year has already expiredfrom the time the certificate of title was
issued toMabini Legaspi pursuant to the alleged sale from thegovernment, said title does
not becomeincontrovertible but is null and void since theacquisition of the property
was in violation of law.

o Further, the petitioner herein is in possession of theland in dispute. Hence, its action to
quiet title isimprescriptible

Grey Alba vs Dela Cruz, 17 Phil 61; GR No. 5246, September 16, 1910

(Land Titles and Deeds – Registration under the Torrens system is a proceeding in rem)

FACTS: Petitioner heirs sought the registration of two parcels of agricultural land and the court
entered a decree directing the registration in favor of the petitioners, as co-owners subject to
the usufructuary rights if the widower of the petitioner’s sister. Respondent tenant filed a
motion for the revision of the case upon the ground that he is the absolute owner of the
disputed lands, having inherited them from his father, who had a state grant for the same.

ISSUE: WON modification of the decree as to exclude said land will prosper.

HELD: No, the main principle of registration is to make registered titles indefeasible. Upon the
presentation in court if an application for the registration of the title to lands, the theory under

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the Torrens system is that all occupants, adjoining owners, adverse claimants, and other
interested persons are notified of the proceedings, and have a right to appear in opposition to
such application. In other words, the proceeding is against the world.

A proceeding is in rem when the object of the action is to bar indifferently all who might be
minded to make an objection of any sort against the right sought to be established, and if
anyone in the world has a right to be heard on the strength of alleging facts which, if true, show
an inconsistent interest.

Republic v. Hon. Umali

G.R. No. 80687, 10 April 1989

Facts:

1) Land in question originally purchased on installment from the government by Florentina

Bobadilla, who transferred her right thereto in favor of Martina Cenizal, et al. Tomasa and Julio
assigned their shares to Martina, Maria and Gregorio, who, in 1971, signed a joint affidavit that
they were entitled to the issuance of a certificate of title over the said land, and that they had
already paid in full.

2) Sec. of Agriculture and Natural Resources executed a deed, and thereafter a TCT. Several
transfers thereafter followed.

3) Republic filed a complaint for reversion on the ground that the original sale of the land was
tainted with fraud based on forgery, and therefore, void ab initio; claimed that Gregorio died in
1943, Maria in 1959, and could not have signed the joint affidavit.

4) Respondent claimed that they all acquired the property in good faith and for value, invoked
estoppel, laches, prescription and res judicata, others invoked no cause of action as no rights
were violated, government not a real party-in-interest because the land is already covered by
Torrens system.

Issue:

May deception/fraud in the registration of title make the sale null and void, so as to make all
titles derived therefrom ineffectual ab initio?

Ruling:

No. The status of the defendants as innocent transferees for value was never questioned, and
such accorded them the protection of the Torrens system, thus rendering the titles obtained
indefeasible and conclusive.

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In the present case, the private respondents acquired the land not by direct grant but in fact
after several transfers following the original sales thereof. They are presumed to be innocent
transferees for value.

The land now being registered under the Torrens system, the government has no more control
or jurisdiction over it; it is no longer part of the public domain.

NB:

A holder in bad faith is not entitled to the protection of the law.

If the patent and the OCT were procured by means of fraud, the land would not revert back to
the State precisely because it has become a private land. The original transfer was not null and
void ab initio but was only voidable. The land remained private as long as the title thereto had
not been voided. In such case, the nullity arises, not from fraud or deceit, but from the fact that
the land is not under the jurisdiction of the Bureau of Lands (now Land Management Bureau).

Sec. 39, Land Registration Act:

Every person receiving a certificate of title in pursuance of a decree of registration, and every
subsequent purchaser of registered land who takes/taking a certificate of title for value in good
faith shall hold the same free of all encumbrance except those noted on said certificate.

Sec. 44, P.D. 1529 – Property Registration Decree:

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 following encumbrances which may be subsisting, and enumerated in law.

Pino vs. CA

G.R. No. 94114

June 19, 1991

FACTS: The decision of the CA affirming in toto the decision of the RTC of Echague, Isabela is
now being assailed in the instant petition for certiorari.

Lot 6 was acquired by the spouses Juan Gaffud and Rafaela Donato. Juan Gaffud died in 1936.
On Jan. 11, 1938, Lot 6 was originally registered (OTC No. 4340) in the Registration Book of the
Office of the RD in the names of Rafaela, Raymundo and Cicero Gaffud (sons of spouses) as co-

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owners, . The said lot was sold to Rafaela Donato through a Deed of Transfer which cancelled
OTC NO. 4340 and in lieu thereof a TCT was issued in the name of Rafaela alone.

On Feb. 1967, Rafaela sold a portion of Lot 6 in favor in Fortunato Pascua. The aforesaid sale
caused the subdivision of the said lot into Lot-6-A and Lot-6-B. Upon registration of said sale in
favor of Pascua, TCT No. T-32683 was issued in the name of Rafaela Donato on March 2, 1967
covering the land designated as Lot 6-B.

On Jun. 10, 1970, Rafaela Donato sold to petitioner Felicisima Pino said Lot-6-B as evidenced by
the Deed of Absolute Sale which was duly notarized. Rafaela undertook to register said Deed
with the RD of Isabela and on July 13, 1970, the sale was inscribed therein and a TCT was issued
in the name of Felicisima Pino.

On Sept. 1980, Cicero Gaffud died survived by his wife Demetrian and sons Romulo and Adolfo,
private respondents herein.

On March 9, 1982, private respondents filed a complaint for nullity of sale and reconveyance
against petitioner — Felicisima Pino. (During the pendency of the case before the trial court,
Rafaela Donato, who was not a party to the case, died on November her 26, 1982.)

The RTC ruled and this was sustained by respondent CA that petitioner Pino is not a purchaser
in good faith, so (a) the Deed of Absolute Sale made by Rafaela in favor of Pino null and void
insofar as the shares of Cicero and Raymundo are concerned, (b) cancellation of TCT No. 49380
in the name of Pino and (c) reconvey one-half of Lot-6-B to plaintiffs withing 10 days.

ISSUE:

1. WON Felicisima Pino is a purchaser in good faith

2. WON the filing of an action for reconveyance has already prescribed

HELD:

1. The rule applicable to this controversy is well-settled. Where the certificate of title is in the
name of the vendor when the land is sold, the vendee for value has the right to rely on what
appears on the certificate of title. In the absence of anything to excite or arouse suspicion, said
vendee is under no obligation to look beyond the certificate and investigate the title of the
vendor appearing on the face of said certificate.

In the case at bar, the evidence on record discloses that when petitioner purchased the subject
property on June 10, 1970, the title was in the name of her vendor Rafaela Donato alone.

There was no allegation, and much less any evidence, that the transfer of the subject property
from the original owners (Rafaela, Cicero and Raymundo) to Rafaela Donato was fraudulent.

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3. TCT No. T-32683 was issued in the name of Rafaela Donato on March 2, 1967. The present
action for reconveyance was filed only on March 9, 1982. Clearly then, the action has already
prescribed because it was filed fifteen (15) years after the issuance of TCT No. T-32683

If an action for reconveyance based on constructive trust cannot reach an innocent purchaser
for value, the remedy of the defrauded party is to bring an action for damages against those
who caused the fraud or were instrumental in depriving him of the property. And it is now well-
settled that such action prescribes in ten years from the issuance of the Torrens Title over the
property. (Armerol v. Bagumbaran, 154 SCRA 396, 407; Caro v. Court of Appeals, 180 SCRA 401,
407; Walstron v. Mapa, Jr., 181 SCRA 431, 442).

Traders Royal Bank vs. Court of Appeals, Patria Capay, et al G.R. No. 118862, Sept. 24, 1999
(315 SCRA 190)

"Torrens System"

"latches"

Facts:

A parcel of land owned by the spouses Capay was mortgage to and subsequently extrajudicially
foreclosed by Traders Royal Bank (TRB). To prevent property sale in public auction, the Capays
filed a petition for preliminary injunction alleging the mortgage was void because they did not
receive the proceeds of the loan. A notice of lis pendens (suit pending) was filed before the
Register of Deeds with the notice recorded in the Day Book. Meanwhile, a foreclosure sale
proceeded with the TRB as the sole and winning bidder. The Capays title was cancelled and a
new one was entered in TRB’s name without the notice of lis pendens carried over the title. The
Capays filed recovery of the property and damages. Court rendered a decision declaring the
mortgage was void for want of consideration and thus cancelled TRB’s title and issued a new
cert. of title for the Capays.

Pending its appeal before the court, TRB sold the land to Santiago who subsequently subdivided
and sold to buyers who were issued title to the land. Court ruled that the subsequent buyers
cannot be considered purchasers for value and in good faith since they purchase the land after it
became a subject in a pending suit before the court. Although the lis pendens notice was not
carried over the titles, its recording in the Day Book constitutes registering of the land and
notice to all persons with adverse claim over the property. TRB was held to be in bad faith upon
selling the property while knowing it is pending for litigation. The Capays were issued the cert.
of title of the land in dispute while TRB is to pay damages to Capays.

Issue:

Who has the better right over the land in dispute?

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Whether or not TRB is liable for damages

Ruling:

The court ruled that a Torrens title is presumed to be valid which purpose is to avoid conflicts of
title to real properties. When the subsequent buyers bought the property there was no lis
pendens annotated on the title. Every person dealing with a registered land may safely rely on
the correctness of the title and is not obliged to interpret what is beyond the face of the
registered title. Hence the court ruled that the subsequent buyers obtained the property from a
clean title in good faith and for value. On one hand, the Capays are guilty of latches. After they
filed the notice for lis pendens, the same was not annotated in the TRB title. They did not take
any action for 15 years to find out the status of the title upon knowing the foreclosure of the
property. In consideration to the declaration of the mortgage as null and void for want of
consideration, the foreclosure proceeding has no legal effect. However, in as much as the
Capays remain to be the real owner of the property it has already been passed to purchasers in
good faith and for value. Therefore, the property cannot be taken away to their prejudice. Thus,
TRB is duty bound to pay the Capays the fair market value of the property at the time they sold
it to Santiago.

Casimiro Development Corporation vs. Renato L. Mateo

G.R. No. 175485, July 17, 2011

FACTS:

In 1988, petitioner purchased from China Bank the land in question which was previously sold
by the mother of Mateo to Rodolfo Pe who in turn constituted a mortgage on the property in
favor of China Bank as security for a loan. China Bank foreclosed the mortgage and consolidated
its ownership of the property after Rodolfo failed to redeem. A TCT was issued in the name of
China Bank. In 1991, CDC brought an action for unlawful detatiner against the respondent’s
siblings. Respondent counters that CDC acquired the property from China Bank in bad faith
because it had actual knowledge of the possession of the property by the respondent and his
siblings.

ISSUE:

WON CDC was an innocent purchaser for value.

HELD:

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. He is charged with notice only of
such burdens and claims as are annotated on the title. China Bank’s TCT’s was a clean title, that

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is, it was free from any lien or encumbrance, CDC had the right to rely, when it purchased the
property, solely upon the face of the certificate of title in the name of China Bank. The
respondent’s siblings’ possession did not translate to an adverse claim of ownership. They even
characterized their possession only as that of mere agricultural tenants. Under no law was
possession grounded on tenancy a status that might create a defect or inflict a law in the title of
the owner. CDC having paid the full and fair price of the land, was an innocent purchaser for
value. The TCT in the name of CDC was declared valid and subsisting.

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