Cruz V

CRUZ V.
NAVARRO
Intentional omission by Navarro to properly inform the
court that there were persons in actual possession and
cultivation of the parcels of land in question constitutes
actual fraud.
REPUBLIC V. LOZADA
Other cases of fraud: Failure of the applicant to disclose
in her application the vital facts that her husband’s
previous application to purchase the lands from the
Bureau of Lands had been rejected, because the lands
were already reserved as a site for school purposes.
a. Concealing that the lands were part of the public
domain and so known to them
b. Deliberate falsehood that the lands were allegedly
inherited by the applicant from her parents.
NOTES ON LAW ON LAND TITLES AND DEEDS
Kenneth & King Hizon (2A)- UST Faculty of Civil Law
Facultad de Derecho Civil 18
UNIVERSITY OF SANTO TOMAS
c. In filing the application for registration in her and

not in that of her husband or the 2 of them jointly.
Petition must be filed within 1 year from entry of
decree of registration
As long as a final decree has not yet been entered by
the Land Registration Authority and the period of 1
year has not elapsed from the date of entry of such
decree, the title is not finally adjudicated and the
decision in the registration case continues to be under
the control of the registration court.
Rule with respect to lands covered by patents
Once the patent is granted and the corresponding
certificate of title is issued, the land ceases to be part of
the public domain and becomes private property over
which the Director of Lands has neither control nor
jurisdiction.
SUMAIL V. JUDGE OF THE CFI OF COTABATO
The date of issuance of the patent corresponds to the
date of the issuance of the decree in ordinary
registration cases.
Q: Under what circumstance may this relief not be
granted?
A:
a. Where the alleged fraud goes into the merits of the
case, is intrinsic and not collateral and has been
controverted and decided; and
b. Fraud consisted in the presentation at the trial of a
supposed forged document, false and perjured
testimony; or in basing the judgment on a
fraudulent compromise agreement; or in the
alleged fraudulent acts or omissions of counsel
which prevented the petitioner from properly
presenting the case.
INNOCENT PURCHASER FOR VALUE AND
IN GOOD FAITH
Q: Who is an Innocent purchaser for value and in good
faith?
A: One who buys property of another, without notice
that some other person has a right to, or interest in,
such property and pays a full and fair price for the
same, at the time of such purchase or before he has
notice of the claim or interest of some other person in
the property.
Q: What does good faith mean?
A: Good faith consists in an honest intention to abstain
from taking any unconscientious advantage of another.
It consists of the possessor’s belief that the person from
whom he received the thing was the owner of the same
and could convey his title.
NOTE: Good faith is presumed.
1. Purchaser charged only with notice of liens noted
on the title
When there is nothing on the certificate of title to
indicate any cloud or vice in the ownership of the
property, or any encumbrance thereon, the purchaser is
not required to explore further than what the Torrens
title upon its face indicates in quest for any hidden
defect that may defeat his title thereto.
A bona fide purchaser for value of property at an
auction sale acquires good title as against a prior
transferee of the same property if such transfer was
unrecorded at the time of the auction sale.
2. Burden of Proof
He who asserts the status of a purchaser in good faith
and for value, has the burden of proving such assertion.
If the complaint does not allege that the purchasers
were purchasers in bad faith or with notice of the
defect in the title of their vendors, there is failure to
state a cause of action, and the purchaser is presumed
to be an innocent purchaser for value and in good faith.
3. Rule of “Caveat emptor”
Q: What is the rule of “caveat emptor”? Explain.
A: One who purchases real property which is in actual
possession of others should, at least, make some
inquiry concerning the rights of those in possession. The
actual possession by people other than the vendor
should put the purchaser upon inquiry.
The rule requires the purchaser to be aware of the
supposed title of the vendor and one who buys without
checking the vendor’s title takes all the risks and losses
consequent to such failure.
Failure to exercise the measure of precaution which
may be required of a prudent man in a like situation, he
cannot be called a purchaser in good faith.
4. Rule applies to mortgages of real property
Q: What does an innocent purchaser for value include?
A:
a. innocent lessee
b. innocent mortgage
c. innocent encumbrancer for value
NOTE: Banks are not required, before accepting a
mortgage, to make an investigation of the title of the
property being given as security. But, banks are
cautioned to exercise more care and prudence in
dealing even with registered lands than private
individuals, for their business is one affected with public
interest, keeping in trust money belonging to their
depositors. Thus, banks are required to investigate who
are the true owners of the land offered as collateral in a
loan.
5. Rule on good faith not absolute; duty of purchaser
to investigate
SANDOVAL V. COURT OF APPEALS
The person dealing with registered land has right to rely
on the Torrens certificate of title and to dispense the
need of inquiring further.
Except: When the party has actual knowledge of facts
and circumstances that would impel a reasonably
cautious man to inquire into the status of the title of the
property.
One who buys from the registered owner need not have
to look behind the certificate of title, he is,
nevertheless, bound by the liens and encumbrances
annotated thereon.
One who buys without checking the vendor’s title takes
all the risks and losses consequent to such failure.
6. A forged deed may be the root of a valid title
Q: Under what circumstance can a forged deed be a
root of a valid title?
A: If the certificate of title has already been transferred
from the name of the true owner to the name of the
forger or the name indicated by the forger.
Every person dealing with registered land may safely
rely on the correctness of the certificate of title issued
in therefor and the law will in no way oblige him to go
behind the certificate to determine the condition of the
property because an innocent purchaser for value
relying on a Torrens title is protected.
7. Good faith is a question of fact
This is a factual matter that will generally be not delved
into by the Supreme Court.
The Supreme Court is not a tier of facts and the factual
findings of the Court of Appeals are binding and
conclusive upon the Court unless:
1. The conclusion is a finding grounded entirely on
speculation, surmise and conjecture.
2. The inference made is manifestly mistaken
3. There is grave abuse of discretion
4. The judgment is based on misapprehension of facts
5. The findings of fact are conflicting
6. CA went beyond the issue of the case and its
findings are contrary to the admissions of both
appellant and appellees
7. The findings of fact of CA are contrary to those of
the trial court
8. Said findings of fact are conclusions without
citation of specific evidence on which they are
based
9. The facts set forth in the petition as well as in the
petitioner’s main and reply briefs are not disputed
by the respondents; and
10. The findings of fact of the CA are premised on the
supposed absence of evidence and contradicted by
the evidence on record.
8. Rule on “Double sale of property”
Question of fact Question of Law
- when the doubt or
difference arises as to the
truth or the falsity of the
statement of facts
-exists when there is
doubt or controversy as to
what the law is on a
certain state of facts
ARTICLE 1544, New Civil Code

If the same thing should have been sold to different
vendees, the ownership shall be transferred to the
person who may have first taken possession thereof in
good faith, if it should be movable property.
Should it be immovable property, the ownership shall
belong to the person acquiring it who in good faith first
recorded it in the Registry of Property.
Should there be no inscription, the ownership shall
pertain to the person who in good faith was first in the
possession; and, in the absence thereof, to the person
who presents the oldest title, provided there is good
faith. (1473)
NOTE: This provision does not apply if the property is
not registered under the Torrens System
RULES OF PREFERENCE
Rules of preference: between 2 buyers of the same
immovable property registered under Torrens System,
the law gives ownership priority to:
1. The first registrant in good faith; then,
2. The possessor in good faith; finally,
3. The buyer who in good faith presents the
oldest title.
Prior registration of the subject property does not by
itself confer ownership or a better right over the
property.
Art.1544 requires that before the second buyer can
obtain priority over the first, he must show that he
acted in good faith from the time he acquired the
property until the title or possession is transferred to
him.
Santiago v. Court of Appeals
Knowledge by the first buyer of the second sale cannot
defeat the first buyer’s rights except when the second
buyer first registers in good faith the second sale.
Conversely, knowledge gained by the second player of
the first sale defeats his rights even if he is first to
register, since such knowledge taints his registration
with bad faith.
Rule contemplates double sale by a single vendor
It is necessary that the conveyance must have been
made by party who has an existing right in the thing and
the power to dispose of it.
It cannot be invoked where the 2 different contracts of
sale are made by 2 different persons, one of them not
being the owner of the property sold.
Where respondents derive their right over their
respective portions either through inheritance or sale
from a particular person while petitioners invoke their
right from sale of the land from another, the law on
double sales does not apply.
“Prior tempore, potir jure” or “he who first in time is
preferred in right”
The only one who can invoke this is the first vendee
Rule of “Prior est temporae, prior est in jura”
Calalang v. Register of Deeds of Quezon City
The fact that Clemente possessed a certificate of title
does not necessarily make him the true owner. Not
being the owner, he cannot transmit any right to nor
transfer any title or interest over the land conveyed.
This is in consonance with the rule “nemo dat quod non
habet” or “no one can give what one does not have.”
The rule that where there are 2 certificates purport to
include the same land, the earlier in date prevails is
valid only absent any anomaly or irregularity tainting
the process of registration.
RECONVEYANCE
An action for reconveyance is a legal and equitable
remedy granted to the rightful owner of land which has
been wrongfully or erroneously registered in the name
of another for the purposes of compelling the latter to
transfer or reconvey the land to him.
The action must be brought after 1 year from the
issuance of the decree.
This does not aim or purport to re-open the registration

proceeding and set aside the decree of registration, but
only show that the person who secured the registration
of the questioned property is not the real owner
thereof.
It only seeks to transfer or reconvey the land from the
registered owner to the rightful owner, it does not seek
to set aside the decree.
Q: What is the statutory basis of the action?
A: Sec. 96 of P.D. 1529.
The registered owner is not rendered immune by the
law from the claim that he is not the real owner of the
land he had registered in his name.
This remedy cannot always be availed of by an
aggrieved claimant, as when the rights of innocent
purchasers for value will be effected.
Nature and purpose of an action for reconveyance
Such action is filed after 1 year from the issuance of the
decree.
It does not aim or purport to re-open the registration
proceeding and set aside the decree of registration, but
only show that the person who secured the registration
of the questioned property is not the real owner
thereof.
It may only take place if the land that is claimed to be
wrongfully registered is still registered in the name of
the person who procured the wrongful registration.
No action for reconveyance can take place as against a
3rd party who had acquired title over the registered
property in good faith and for value.
Decree becomes incontrovertible after 1 yr. from
issuance of decree; remedy of reconveyance
The basic rule is that after the lapse of 1 year, a decree
of registration is no longer open to review or attack
although its issuance is attended with actual fraud.
If the property has not yet passed to an innocent
purchaser for value, an action for reconveyance is still
available.
An action for reconveyance is an action in personam
if the property has passed into the hands of an
innocent purchaser for value, the remedy is an action
for damages.
A Torrens Title cannot be collaterally attacked. The
issue on the validity of the title can only be raised in an
action expressly instituted for that purpose. The attack
must be direct.
Art. 1456 of the New Civil Code provides that a person
acquiring the property through fraud becomes by
operation of law a trustee of an implied trust for the
benefit of the real owner of the property.
Remedy available even before issuance of decree
The party who is prejudiced may file an action for
reconveyance of the property of which he had been
illegally deprived, even before the issuance of the
decree.
RELEVANT ALLEGATIONS
The following must be alleged to entitle the plaintiff to
recover title:
a. That the plaintiff was the owner of the land;
b. That the defendant had illegally dispossessed
him of the same.
NOTE: The body of the pleading or complaint
determines the nature of the action, not its title or
heading.
RECONVEYANCE IS AN ACTION IN PERSONAM
A judgment therein is binding only upon the parties
properly impleaded and duly heard or given an
opportunity to be heard.
Action in personam Action in rem
Directed against specific
persons and seek
personal judgments.
Directed against the thing
or property or status of a
person and seek
judgments with respect
thereto as against the
whole world.
Being an action in personam, it is important that the

court must have jurisdiction over the person of the
defendant, otherwise, its judgment is null and void.
Notice of Lis pendens- may be annotated on the
certificate of title immediately upon the institution of
the action in court. It will avoid the transfer to an
innocent third person for value and preserve the claim
of the real owner.
Q: Where to file action?
A: RTC has exclusive original jurisdiction in all civil
actions which involve the title to or any interest in
property where the assessed value exceeds P20,000.00,
or in Metropolitan Manila, where such value exceeds
P50,000.00. The Municipal Trial Court has jurisdiction
over the case if it involves a market value of P15,000.00.
INDISPENSABLE PARTIES TO BE IMPLEADED
Owners of the property are indispensable parties.
Q: Who is an indispensable party?
A: One without whom the action cannot be finally
determined, whose interests in the subject matter of
the suit and in the relief sought are so bound up with
that of the other parties that his legal presence as a
party to the proceeding is an absolute necessity.
Action for reconveyance may be barred by Statute of
Limitations
The action prescribes after 10 years, since it is an action
based upon an obligation created by law.
The period is counted from the date the adverse title to
property is asserted by the possessor thereof. This
assertion of adverse title takes place upon the
registration constitutes constructive notice to 3rd
persons. Registration of a certificate of title constitutes
constructive notice to the whole world.
PRESCRIPTION OF ACTION
Action based on fraud 10 years
Action based on implied
trust
10 years
Action based on a void
contract
Imprescriptible
Action based on a Imprescriptible
fictitious deed
Action to quiet title where
plaintiff is in possession
Imprescriptible
LACHES MAY BAR RECOVERY
Q: What are the 4 elements of laches?
A:
1. Conduct on the part of the defendant, or of one
under whom her of one under whom he claims,
giving rise to the situation of which complaint is
made and for which the complaint seeks a remedy;
2. Delay in asserting the complainant’s rights, the
complainant having had knowledge or notice, of the
defendant’s conduct and having been afforded an
opportunity to institute a suit;
3. Lack of knowledge or notice on the part of the
defendant that the complainant would assert the
right on which he bases his suit; and
4. Injury or prejudice to the defendant in the event
relief is accorded to the complainant, or the suit is
not held to be barred.
Q: Explain the principle of Laches?
A: It is one of estoppel because it prevents people who
have slept on their rights from prejudicing the rights of
3rd parties who have placed reliance on the inaction of
the original patentee and his successors in interest.
ACTION MAY BE BARRED BY RES JUDICATA
When a court of competent jurisdiction has tried and
decided a right or fact, so long as the decision remains
unreversed, it is conclusive on the parties and those in
privity with them.
Q: What are the elements of res judicata?
A:
1. The former judgment must be final;
2. The court which rendered it had jurisdiction
over the subject matter and the parties;
3. The judgment must be on the merits; and
4. There must be between the first and the second
actions, identity of the parties, subject matter,
and causes of action.
NOTE: Res Judicata does not require absolute identity

of the parties but merely substantial identity of parties.
Q: When is there no substantial identity of parties?
A: When there is community of interest or privity of
interest between a party in the first and a party in the
second case even if the first case did not implead the
latter.
NOTE: The State is not barred by prescription
Reconveyance of land acquired through homestead or
free patent
The rule that a homestead patent or free patent, once
registered, becomes indefeasible is true only if the
parcel of agricultural land granted by the government,
after the requirements of the law had been
accomplished with, was a part of public domain.
If it was not but a private land, the patent granted and
the torrens title issued upon the patent or homestead
grant are a nullity
Proof of identity and ownership indispensable
The person who claims that he has better right to a real
property must prove not only his ownership of the
same, he must also satisfactorily prove the identity
thereof. Otherwise, his failure to prove the identity of
the property he claims will result to the failure of his
action for reconveyance.
QUIETING OF TITLE
Q: When can an action for quieting of title be filed?
A: When there is a cloud in title to real property or any
interest therein, by reason of any instrument, record,
claim, encumbrance or proceedings which is apparently
valid or effective but is in truth and in fact invalid,
voidable or unenforceable, and may be prejudicial to
said title, an action may be brought to remove such
cloud or to quiet the title. An action may also be
brought to prevent a cloud from being cast upon title to
real property or any interest therein.
f
CLOUD ON TITLE
Q: Explain the concept of a cloud on title.
A: An outstanding claim or encumbrance which, if valid,
would affect or impair the title of the owner of a
particular estate; but it can be shown by extrinsic proof
to be invalid or inapplicable to the estate in question.
TRUST
Q: Explain the concept of trust?
A: Trust is the legal relationship between one person,
having an equitable ownership in property and another
person owning the legal title to such property; such
equitable ownership of the former entitles him to the
performance of certain duties and the exercise of
certain powers by the latter.
Q: Distinguish between express and implied trust.
EXPRESS TRUST IMPLIED TRUST
- created by direct and positive
acts of the parties; writing or
deed or will or by words
evidencing an intention to
create a trust.
- those which, without being
express, are deducible from the
nature of the transaction as
matters of intent or which are
superinduced on the transaction
by operation of law. It could
either be resulting or
constructive trusts.
a. Resulting trusts-based on
the equitable doctrine that
the valuable consideration
and not the legal title
determines the equitable
title or interest and are
presumed always to have
been contemplated by the
parties.
b. Constructive trusts-created
by the construction of
equity in order to satisfy the
demands of justice and
prevent unjust enrichment.
Prescription arising from implied or constructive trust
The rule that a trustee cannot acquire by prescription
ownership over the property entrusted to him until and
unless he repudiates the trust, applies to express trust
and resulting implied trust.
In constructive implied trusts, prescription may
supervene even if trustee does not repudiate the
relationship.
Repudiation of the said trust is not a condition
precedent to the running of the prescriptive period.
Prescriptive period for the action to reconvey the title

to real property arising from implied or constructive
trust is 10 years, counted from the date of the issuance
of certificate of title over the real property.
Art. 1144 of the New Civil Code
The following actions must be brought within ten years
from the time the right of action accrues:
(1) Upon a written contract;
(2) Upon an obligation created by law;
(3) Upon a judgment. (n)
However, if the person claiming to be the owner of the
land is in actual possession thereof, the right to seek
reconveyance does not prescribe.
In an action for reconveyance, decree of registration is
respected as incontrovertible. What is sought instead is
the transfer of the property, which has been wrongfully
or erroneously registered in another person’s name to
the rightful owner.
A constructive trust, unlike an express trust does not
emanate from, or generate a fiduciary relation. While
an express trust, a beneficiary and a trustee are linked
by confidential or fiduciary relations, in a constructive
trust, there is neither a promise nor any fiduciary
relation to speak of and so-called trustee neither
accepts any trust nor intends holding the property for
the fiduciary.
ACTION FOR DAMAGES
An action for reconveyance is not feasible where the
property has already passed into the hands of an
innocent purchaser for value. But the interested party
may file an action for damages against the persons
responsible for depriving him of his right or interest in
the property.
This action should be brought within 10 years from the
date of the issuance of the questioned certificate of title
pursuant to Art. 1144 of NCC.
ACTION FOR REVERSION
Reversion connotes restoration of public land
fraudulently awarded or disposed of to the mass of the
public domain and may again be the subject of
disposition in the manner prescribed by law to qualified
applicants.
It is instituted by the government, through the Solicitor
General. But an action for cancellation, not reversion, is
a proper where private land had been subsequently
titled, and the party plaintiff in this case is the prior
rightful owner of the property.
The Director of Lands has a continuing authority to
conduct investigation, from time to time, to determine
whether or not public land has been fraudulently
awarded or titled to the end that the corresponding
certificate of title be cancelled and the land reverted to
the public domain.
The government is not estopped by the error or mistake
of its agents, not barred by prescription.
Where the land covered was still within the forest zone
or under the jurisdiction of the Bureau of Forestry, the
Director of Lands had no jurisdiction to dispose of said
land.
Q: Who initiates the action for reversion?
A: An action for reversion is instituted by the Solicitor
General. The Office of the Solicitor General shall
represent the government, its agencies, and
instrumentalities, and its officials and agents in any
litigation, proceeding, investigation or matter requiring
the services of a lawyer. It shall represent the
government in all registration and related proceedings
and institute actions for the reversion to the State of
Lands of the public domain and improvements thereon
and all lands held in violation of the Constitution.
ACTION FOR REVERSION v. ESCHEAT PROCEEDINGS
Q: Differentiate for action for reversion and escheat
proceedings.
ACTION FOR
REVERSION
ESCHEAT PROCEEDINGS
-expressly authorized by
the Public Land Act
-may be instituted as a
consequence of a violation of
the Constitution which
prohibits transfers of private
agricultural lands to aliens
Grounds for reversion
Q: What are the grounds for reversion?

A: Violations of the ff:
a. Sec. 118 of CA No. 141- no alienation, transfer, or
conveyance of any homestead after 5 years and
before 25 years after issuance of title shall be valid
without the approval of the Sec. of Environment
and Natural Resources.
b. Sec. 120- conveyances and encumbrances made by
persons belonging to the so-called non-Christian
tribes, shall be valid if the person making the
conveyance or encumbrance is able to read and can
understand the language in which the instrument of
conveyance or encumbrance is written. It must be
duly approved by the Commission on National
Integration.
c. Sec. 121- No corporation, association, or
partnership may acquire or have any right, title,
interest, or property right whatsoever to any land
granted under the free patent, homestead, or
individual sale or to any permanent improvement
on such land.
NOTE: Under the present Constitution, with the
exception of agricultural lands, all other natural
resources shall not be alienated. Moreover, private
corporations or associations may not hold alienable
lands of the public domain except by lease for a period
not exceeding 25 years, renewable for not more than 25
years, and not exceed 1,000 hectares in area. Citizens of
the Phil. may lease not more than 500 hectares, or
acquire not more than 12 hectares thereof by purchase,
homestead, or grant.
State not barred by res judicata
 A patent is void at law if the officer who issued the
patent had no authority to do so.
 The certificate of title issued pursuant to a void
patent may be ordered cancelled and the land
reverted to the State through an action for
reversion. This action cannot be barred by prior
judgment of said court since it had no jurisdiction
over the subject matter (Republic v. Dela Cruz).
State not barred by estoppel
 The Director of Forest Development is the
official clothed with jurisdiction and authority over
the demarcation, protection, management,
reproduction, reforestation, occupancy, and use of
all forests and forest resources. Even granting that
the said official was negligent, the doctrine of
estoppel, cannot operate against the State.
CANCELLATION OF TITLE
ACTION FOR REVERSION ACTION FOR
CANCELLATION
- filed by the
government through the
Solicitor General
-initiated by a private party
usually in a case where
there are 2 titles issued to
different persons for the
same lot
Q: When there are 2 titles issued, what should the
authority do?
A: When one of the 2 titles is held to be superior over
the other, one should be declared null and void and
ordered its cancellation.
 If a party is adjudged to be the owner, pursuant to a
valid certificate of title, said party is entitled to
possession of the land covered by the title.
Q: In the remedy of action for cancellation of title,
does the land revert back to the mass of public
domain?
A: In this action, the land does not revert to the mass of
the public domain, but is declared as lawfully belonging
to the party whose certificate of title is held superior
over the other.
Q: What is the rule when 2 or more certificates of title
are issued?
A: The rule is, where there are 2 certificates of title
issued, the earlier in date must prevail as between the
original parties, and in case of successive registration
where more than 1 certificate is issued over the land,
the person holding under the prior certificate is entitled
to the land, as against the person who relies on the
second certificate.
RECOVERY FROM THE ASSURANCE FUND
 This remedy is stated under Sec. 95 of Property
Registration Public policy and public order demand
not only that litigations must terminate at some
definite point but also that titles over the lands
under the Torrens System should be given stability
for on it greatly depends the stability of the

country’s economy.
 Exception: Public policy also dictates that those
unjustly deprived of their rights over real property
by reason of the operation of our registration laws
be afforded remedies.
 Aggrieved party may file action for reconveyance of
property or personal action for recovery of damages
against the party who registered his property
through fraud, or in case of insolvency who
procured the registration through fraud, an action
against the Treasurer of the Philippines for
recovery of damages from the Assurance Fraud.
 This is to prevent unjust enrichment of one party at
the expense of another.
Requisites for recovery from Assurance Fund
Q: What are the requisites for recovery from the
Assurance Fund?
A:
1. That a person sustains loss or damage, or is
deprived of any estate or interest in land
2. On account of the bringing of land under the
operation of Torrens System arising after original
registration
3. Through fraud, error, omission, mistake or
misdescription in any certificate title or in any entry
or memorandum in the registration book
4. Without negligence on his part
5. Is barred or precluded from bringing an action for
the recovery of such land or estate or interest
therein.
 It is necessary that there be no negligence on the
part sustaining any loss or damage or being
deprived of any land or interest therein after
original registration.
Deprivation of land or interest therein
 To afford relief from the assurance fund, the
plaintiff must have sustained loss or damage or
deprived of any estate in the land.
Q: Explain the requirement of good faith.
A: The person who brings an action for damages against
the Assurance Fund should be the registered owner,
and, as to holders of transfer certificates of title, that
they be innocent purchasers in good faith and for value.
Sec. 95 requires that the person who claims damages
should not have been negligent in acquiring the
property or in obtaining the registration thereof in his
name.
ANNULMENT OF JUDGMENTS OR FINAL ORDE

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CRUZ V.

c. In filing the application for registration in her and

ARTICLE 1544, New Civil Code

This does not aim or purport to re-open the registration

Being an action in personam, it is important that the

NOTE: Res Judicata does not require absolute identity

Prescriptive period for the action to reconvey the title

Q: What are the grounds for reversion?

for on it greatly depends the stability of the

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