Sps. Mathay v CA Recit: Facts: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

Tomas Lucido got a sales patent from the bureau of lands of Lot 2186 covering 174,914 sq.m. Tomas Lucido assigned his rights to two persons Batallones and Quimio. The assignment was approved and a Sales Certificate was issued. The heirs of Batallones and Quimio were given TCT No. 85866 on AUGUST 9, 1976. Lucido filed a case against Quimio and Batallones saying that the assignment was void but later they agreed to enter into a compromise. Lucido got 2 parcels of land. TCT No. 2186A and 2186B; Batallones, C and D; Quimio, E and F. Lucidos lands were sold to Atangan on JULY 24, 1985; Batalloness to poblete and Tirona; Quimios to Sps. Motas. The purchasers paid taxes as evidenced by their tax declarations and tax receipts from 1985 The purchasers also had actual possession of the land Sps. Mathay Claimed to have a Certificate of title which was acquired from Banayo and Pugay on FEBRUARY 28, 1980 and May 31, 1980 who acquired the Original Certificate of Title after applying for the same because of the assignment of rights by Tomas Lucido to them . Sps. Mathay sent armed men who tried to fence the land and dispossessed Atangan of his land.

11. Issues:

1. Are the Sps. Mathay considered Innocent Purchaser for Value? 2. Who has the better right over the land? Held: 1. No. While the TCT given to Sps. Mathay is valid and it forgery was not proven, they cannot be considered innocent purchasers for value relying on the mirror doctrine, because at the time of the purchase there were already occupants to the land. That actual knowledge of facts and circumstances which impel a reasonably prudent man to inquire and investigate the extent of the possessory rights of the occupants. It should have put Sps. Mathay on guard and failure on his part precludes him from invoking the rights of a Purchaser in Good faith. 2. In the case of MWSS v CA the Supreme Court ruled that if there are two valid certificates of title issued on the same land, that with the earlier date prevails. While that is the general rule, in successive registrations where more than one certificate of title in the same land the basis should be the right derived from the earliest holder of certificate to the land. The better approach is to trace the original certificate or derivative title. Illustration: Pag ginamit yung unang approach, panalo si Sps. Mathay kase Nakuha nila yung TCT nung 1980 samantalang si Atangan 1985 lang. Yung sinunod na ruling ay ginamit yung derivative title nung August 1976 kaya mas una na si Atangan kaysa kay Mathay.. =)