Facts:

The case involves Ma. Kristel B. Aguirre (petitioner) and Cristina B. Bombaes (respondent). The dispute centers around a parcel of land known as Lot No. 782 located in Roxas City, which was originally covered by Transfer Certificate of Title (TCT) No. T-41765 in the name of the respondent. On March 17, 2008, the respondent mortgaged Lot No. 782 to Vicente Atlas Catalan (Catalan) to secure a loan of P1,350,000.00, with a 5% monthly interest due on September 24, 2008. The respondent defaulted on her loan, leading to the execution of a Deed of Absolute Sale on October 19, 2009, transferring the property to Catalan. Subsequently, on November 26, 2009, the title was transferred to Catalan under TCT No. T-58922.

On April 9, 2010, the petitioner offered to purchase Lot No. 782 from Catalan, who agreed and executed a Deed of Conditional Sale. This was followed by a Deed of Absolute Sale on May 4, 2010, after the petitioner paid the full purchase price. The property was then regist...

Facts:

Background of the Property

• The case involves a parcel of land, Lot No. 782, located in Roxas City, previously covered by Transfer Certificate of Title (TCT) No. T-41765 under the name of Cristina B. Bombaes (respondent).

Mortgage and Default

• On March 17, 2008, respondent mortgaged Lot No. 782 to Vicente Atlas Catalan (Catalan) to secure a loan of P1,350,000.00 with 5% monthly interest, payable on September 24, 2008. Respondent defaulted on the loan.

Execution of Deed of Absolute Sale

• On October 19, 2009, respondent and Catalan executed a Deed of Absolute Sale over the property in favor of Catalan. Title was transferred to Catalan under TCT No. T-58922 on November 26, 2009.

Sale to Petitioner

• On April 9, 2010, Ma. Kristel B. Aguirre (petitioner) offered to purchase the property from Catalan. They executed a Deed of Conditional Sale on the same day, followed by a Deed of Absolute Sale on May 4, 2010, after petitioner paid the purchase price. The property was registered under TCT No. 097-2010000326 in petitioner's name.

Respondent's Claim

• Respondent filed a complaint for quieting of title, alleging that the Deed of Absolute Sale was simulated and that Catalan coerced her into signing it. She claimed the sale was intended to allow Catalan to mortgage the property and apply the proceeds to her unpaid loan. She also executed a deed of assignment to guarantee her right to redeem the property.

Catalan's Defense

• Catalan denied coercion and stated that respondent signed the Deed of Absolute Sale, an acknowledgment receipt, and a deed of confirmation. He claimed the sale was valid and that he needed funds for his mayoral campaign.

Petitioner's Defense

• Petitioner asserted she was an innocent purchaser for value, having relied on Catalan's clean title at the time of the sale. She had no knowledge of any prior claims or interests over the property.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Timeliness of Motion for Reconsideration: The Court held that respondent's Motion for Reconsideration was filed within the reglementary period, as evidenced by the registry receipt and Postmaster's Certification.

2. Innocent Purchaser for Value:

   • An innocent purchaser for value is one who buys property without notice of any defect or claim and pays a full and fair price.
   • Petitioner relied on Catalan's clean title (TCT No. T-58922), which had no adverse claims or encumbrances at the time of the sale.
   • The adverse claim was annotated on May 12, 2010, eight days after the Deed of Absolute Sale was executed on May 4, 2010. Thus, petitioner had no notice of any defect or claim at the time of purchase.
   • The Court emphasized that under the Torrens system, a buyer may rely on the correctness of the certificate of title unless there is evidence of fraud or knowledge of a defect.

3. Public Policy and Recourse for Respondent:

   • While petitioner's title is upheld, respondent may seek compensation from the Assurance Fund under Section 95 of Presidential Decree No. 1529 (Property Registration Decree) for the loss of her property.

Conclusion:

• The Supreme Court granted the petition, reversed the CA's Amended Decision, and reinstated the CA's original Decision, affirming petitioner's status as an innocent purchaser in good faith and for value.