Uy vs. Fule (G.R. No.

164961, June 30, 2014)

FACTS: Conrado Garcia, upon his death, his heirs had entered an extrajudicial settlement of his estate
including the land and thereafter caused its registration under their names. Meanwhile,DAR officials
issued a joint certification that said land was an “untitled” property owned by CG.As such, it was then
included in the Operation Land Transfer program pursuant to PD No. 27.The offices issued Emancipation
Patents and Original Certificate of Titles to farmer-beneficiaries like Mariano Ronda (MR). MR sold his
portion to Chisan Uy then Chisan Uy’s heirs, sold the said land to Hector Uy. In 1997, the TCT of CG was
cancelled and subsequently issued in the names of the heirs of Garcia under a new TCT. In 1998, DAR
Secretary issued the EPs to farmer beneficiaries like MR. However, CG’s TCT was already in the name of
Hector Uy. Because of this, the heirs of CG filed a complaint assailing the certificates of titles issued to
purchasers Chisan and Hector Uy. RTC favored respondents. CA affirmed. SC affirmed CA.

Issue: Whether or not Hector Uy, who got the land from the heirs of the farmer beneficiary Mariano
Ronda, was an innocent purchaser for value

Held:

Here, the deed of sale executed between the heirs of Ronda and the petitioner were issued only on
August 17, 1998 but the deed of sale was executed on July 31, 1998. Evidently, the petitioner entered
into the deed of sale without having been able to inspect the TCTs since they were still inexistent. His
only basis were the OCTs and such categorically stated that they were entered pursuant to an
emancipation patent pursuant to Operation Land Transfer. It provided that it shall not be transferred
except by hereditary succession or to the government. Generally, a buyer is not required to inquire
beyond the title if the requisites of good faith concur. However, absent one or two of the requisites,
then the law itself puts the buyer onNotice and obliges the latter to exercise a higher degree of diligence
by scrutinizing the certificate of title and examining all factual circumstances in order to determine the
seller’s title and capacity to transfer any interest in the property.
ABLO M. PADILLA, JR. and MARIA LUISA P. PADILLA, VS vs. LEOPOLDO MALICSI, LITO CASINO,
and AGRIFINO GUANES (G.R. No. 201354 )

Facts: Spouses Padilla purchase a parcel of land in Cabanatuan City. In 1983, the spouses learned that
the respondents constructed houses on their lot repeated verbal and written demands was made by
spouses to vacate the premises and pay monthly rental but the respondents refused to care their
demands. The matter was referred to the Katarungang Pambarangay for conciliation proceedings but
failed. The spouses filed a complaint for recovery of possession against respondents. The latter alleged
that they believed inall honesty and good faith that the lot belonged to Toribia Vda. de Mosses geld, and
claimed that theybuilt their houses after receiving Toribia's permission. Respondents also claimed that
they and Toribia agreed that she would sell them the areas they occupied. They stated that they first
found out about the spouses' claim of ownership sometime in 2002. They admitted receiving the
demand letters to vacate and pay rentals, but they refused to leave the premises. In 2009, the spouses
filed a motion with offer to sell, exercising their option to sell the land under Art. 448 of the Civil Code,
which in effect, recognized the respondents as builders in good faith. They did not accept the offer
Issues: Whether the respondents are builders in good faith.
Ruling: No. A builder in good faith is a builder who was not aware of a defect or flaw in his or her title
when he introduced improvements on a lot that turns out to be owned by another. Jurisprudence
provides that the burden of proving the status of a purchaser in good faith lies on the person declaring
that status. It is insufficient to invoke the ordinary presumption of good faith; that is, that everyone is
presumed to act in good faith. To support their claim, respondents claim that they were made to believe
by Toribia that she owned the lot. Respondents also claim that they received permission from Toribia to
build their houses on the land, subject to their eventual purchase of the portions where their houses
stood. However, aside from this naked and self-serving testimony, respondents failed to present any
evidence to bolster their claim. Furthermore, respondents neither presented Toribia herself nor
submitted proof on which she might have based her purported ownership of the lot. Respondents
likewise failed to prove that they exercised the necessary diligence required by their situation. They did
not examine the tax declarations or the title to the property before they built on it. Failing to
substantiate their claim, respondents cannot be considered as builders in good faith.
Emilio Calma vs. Atty. Jose Lachica, Jr.
G.R. No. 222031
FACTS: Respondent Atty. Jose Lachica claims to be the owner of a 20,000 sq.m. parcel of land in
Cabanatuan City covered by TCT No. T-28380, having acquired the same through sale from Ceferino
Tolentino. The title to said property was also delivered to him in 1974 and he has been in actual physical
possession of the property since then. However, the 1974 Deed of Sale was lost so the parties executed
anew Deed of Sale executed on April 29, 1979. Respondent had to travel to far-away places because of
his job in the government but he continued to possess the entire property through his helper. In 1981,
he caused the annotation of a Notice of Adverse Claim on TCT No. T-28380. After the notarization of the
1979Deed of Sale in 1986, Ceferino and his son Ricardo requested respondent to allow them to cultivate
the5,000 sq.m. portion of the subject land and in consideration, they would process the transfer of the
title to respondent’s name. Respondent agreed out of trust. In 2001, respondent returned to
Cabanatuan and found that title to the property was transferred to Ricardo’s name, which was in turn
cancelled and transferred under petitioner Emilio Calma’s name. Respondent argued that the sale
between Ceferino and Ricardo was null and void for being executed with fraud and that that not only
was Ricardo in full knowledge of the sale of the subject property to him by Ceferino, but also his adverse
claim was evidently annotated in the latter's title and carried over to Ricardo's title. Respondent filed a
petition for the annulment of deeds of sale and cancellation of title petitioner.
ISSUE: Whether or not respondent Calma is a buyer in good faith
Ruling:
Every person dealing with registered land may safely rely on the correctness of the COT issued therefor
and is in no way obliged to go beyond it to determine the condition of the property unless the party has
knowledge of a defect or the lack of title in his vendor or of facts and circumstances that would impel a
reasonably cautious man to make further inquiry. In the case at bar, petitioner was never remiss in his
duty of ensuring that the property that he was going to purchase had a clean title. Despite Ricardo's title
being clean on its face, petitioner still conducted an investigation to check its authenticity and status
with the RD and the mortgagee-bank. Thus, petitioner was proven to be in good faith. The CA’s
conclusion that the annotation of the adverse claim on Ceferino's title and carried over to Ricardo's title
for a total of 13 years before it was cancelled should have aroused suspicion have no factual or legal
basis. What is essential on the matter of petitioner's good faith in the acquisition of the subject property
is the cancellation of such adverse claim, which clearly appears on the face of Ricardo's title. Even the
defect in Ricardo's title due to his bad faith in the acquisition of the subject property, as found by both
the RTC the CA, should not affect petitioner's rights as an innocent purchaser for value. Under Article
1544 of the Civil Code, petitioner's right as an innocent purchaser for value who was able to register his
acquisition of the subject property should prevail over the unregistered sale of the same to the
respondent.
LOCSIN vs. HIZON
G.R. No. 204369
Facts: Petitioner Enriqueta M. Locsin (Locsin) was the registered owner of a 760-sq.m. in Don Antonio
Heights Subdivision, Quezon City. 1992: She filed an ejectment case against Aceron. Eventually, the two
entered into a compromise agreement. Locsin later went to the United States without knowing whether
Aceron has complied with his part of the bargain under the compromise agreement. In spite of her
absence, however, she continued to pay the real property taxes on the subject lot. 1994: After
discovering that her copy of her TCT was missing, Locsin filed a petition for administrative reconstruction
to secure a new one (TCT No. RT-97467). Early 2002: she then requested her counsel to check the
status of the subject lot. It was then that they discovered the following One Marylou Bolos (Bolos) had
TCT No. RT-97467 cancelled and secured a new one by registering a Deed of Absolute Sale dated
November 3, 1979 allegedly executed by Locsin.o Bolos later sold the subject lot to Bernardo Hizon for
PhP1.5 million, but it was titled under his son, Carlos Hizon, on August 12, 1999.o Bernardo, claiming to
be the owner of the property, filed a Motion for Issuance of Writ of Execution for the enforcement of
the court-approved compromise agreement in the previous ejectment case. May 9, 2002: Locsin sent
Carlos a letter requesting the return of the property since her signature in the purported deed of sale in
favor of Bolos was a forgery. In a letter-reply Carlos denied Locsin’s request, claiming that he was
unaware of any defect or flaw in Bolos’ title and he is, thus, an innocent purchaser for value and good
faith. June 2002: Locsin met with Bernardo for a possibility of compromise. BUT, in July 2002: Locsin
learned that Carlos had already sold the property for PhP 1.5 million to his sister and her husband
(Spouses Guevara). But it was as early as May 24, 2002 when a new TCT was issued in their names.
Spouses Guevara then immediately mortgaged the said property to secure a PhP2.5 million loan/credit
facility with Damar Credit Corporation (DCC). Locsin filed an action for reconveyance, annulment of
title, cancellation of the mortgage lien annotated thereon, and damages

Issue: Whether or not respondents are innocent purchasers for value.

Ruling: Carlos and Guevara are not innocent purchasers for value. The circumstances in this case, taken
altogether, strongly indicate that Carlos and the spouses Guevara failed to exercise the necessary level
of caution expected of a bona fide buyer and even performed acts that are highly suspect Bernardo and
Carlos should have been impelled to investigate the reason behind the arrangement. They should have
been pressed to inquire into the status of the title of the property in litigation in order to protect Carlos’
interest. It should have struck them as odd that it was Locsin, not Bolos, who sought the recovery of
possession by commencing an ejectment case against Aceron, and even entered into a compromise
agreement with the latter years after the purported sale in Bolos’ favor. Instead, Bernardo and Carlos
took inconsistent positions when they argued for the validity of the transfer of the property in favor of
Bolos, but in the same breath prayed for the enforcement of the compromise agreement entered into
by Locsin.
Title: Bernales vs IAC
Petitioners allege that that Dagaoan Sawadan acquired ownership over subject property by way of
continuous, adverse and peaceful possession since time immemorial. Augusto Siagan inherited the
subject lot nevertheless his son purported that a Deed of Absolute Sale he inherited from his late
grandmother indicated that it was sold to the Pasimio spouses and the instrument was registered. The
Pasimio spouses on the other hand sold the same lot to the Roman Catholic Bishop of Bangued, Inc. who
purchase such lot for reason of disposing the same at cost to the actual occupants-tenants. Said tenants
are now the petitioner’s herein .Elpidio Siagan applied a Free Patent over said lot on 1968 where an
original certificate of title covering was issued in his name. Spouses Cadiam purchase such from Elpidio,
and the TCT was issued in their names. Now Cadiam spouses has the possession of the land where they
fenced it and rice was plante there but herein petitioners on, compulsorily evicted them uprooting the
plants. This pave way to the transfer of the criminal charge to the Court of Agrarian Relations
nonetheless because petitioners claimed ownership, filed a civil action for a recovery of ownership of
the same lot was filed by spouses Cadiam.
ISSUE: Whether or not the spouses Cadiam have a better title over the disputed land than Bernales And
his co-plaintiffs
Ruling: Yes Here,the Cadiam spouses who were favored by the Court of Appeals as innocent purchasers
for value with a Transfer Certificate of Title under the Torrens System issued in their names, have
clearly a better right than petitioners. The Cadiam spouses where a Transfer Certificate of Title was
issued after the purchase of the lot from Elpidio Siagan for a valuable consideration as stated in the
Deed and who had not learned of any defect or imperfection of the title during the time it was
purchased, are obviously, innocent purchasers for value, and the same time are protected by the law.