Case Digest (G.R. No. 25694)
Facts:
The case involves Leocadia Angelo as the applicant and the Director of Lands, along with claimants Lucia F. de Valle Cruz and Cipriano Pacheco, as the appellees. The events leading to this case began on July 2, 1920, when Leocadia Angelo applied for the registration of 659 hectares of land located in the barrios of Barang and Mabilang in the municipality of Paniqui, Tarlac. The application did not reach a final hearing until September 20, 1923, when the Court of First Instance of Tarlac ordered the registration of the land in favor of Angelo. A final decree was issued on July 16, 1924, and a certificate of title was granted to her two days later. Subsequently, Leocadia executed a deed of sale for the land to Cipriano Pacheco, who received Transfer Certificate of Title No. 786 from the registry of deeds of Tarlac. Shortly thereafter, on July 23, 1924, Pacheco sold the land to Lucia F. de Valle Cruz for P15,000, with a pacto de retro for five years, while remaining in possessio...
Case Digest (G.R. No. 25694)
Facts:
Application for Land Registration:
- On July 2, 1920, Leocadia Angelo applied for the registration of 659 hectares of land located in Barang and Mabilang, Paniqui, Tarlac.
- The case was heard on September 20, 1923, and a decision was rendered ordering the registration of the land in favor of Leocadia Angelo.
- A final decree was issued on July 16, 1924, and a certificate of title was issued to Leocadia Angelo on July 18, 1924.
Sale of the Land:
- Leocadia Angelo sold the land to Cipriano Pacheco, who received Transfer Certificate of Title No. 786.
- On July 23, 1924, Cipriano Pacheco executed a deed of sale with pacto de retro in favor of Lucia F. de Valle Cruz for P15,000, with a five-year redemption period.
- The deed included a provision allowing Pacheco to remain in possession of the land as a tenant, paying P150 monthly rent.
Petition for Review:
- On October 6, 1924, the Director of Lands and numerous adverse claimants filed petitions for review under Section 38 of the Land Registration Act.
- They alleged that the registration was obtained by fraud, as Leocadia Angelo falsely claimed sole possession of the land, and the adverse claimants were not notified of the registration proceedings.
Trial Court Decision:
- The Court of First Instance of Tarlac found that Leocadia Angelo obtained the decree by fraud.
- The court declared the decree null and void, canceled Pacheco’s transfer certificate of title, and ruled that Lucia F. de Valle Cruz’s good faith was doubtful.
Appeal:
- Both Cipriano Pacheco and Lucia F. de Valle Cruz appealed the decision.
Issue:
- Whether the registration of the land in favor of Leocadia Angelo was obtained by fraud.
- Whether Cipriano Pacheco and Lucia F. de Valle Cruz were innocent purchasers for value.
- Whether the decree of registration could be reopened under Section 38 of the Land Registration Act, considering the rights of an innocent mortgagee.
Ruling:
Fraud in Registration:
- The Supreme Court affirmed that the registration was obtained by fraud. Leocadia Angelo falsely claimed sole possession of the land, and the adverse claimants were deprived of notice and the opportunity to assert their rights.
Innocent Purchaser for Value:
- Cipriano Pacheco was not an innocent purchaser for value, as he had knowledge of the fraudulent circumstances.
- Lucia F. de Valle Cruz, however, was found to be an innocent mortgagee for value, as there was no evidence of bad faith on her part.
Modification of the Trial Court’s Decision:
- The Supreme Court modified the trial court’s decision, declaring that Lucia F. de Valle Cruz’s lien on the land for P15,000, with 12% annual interest, must be respected.
- The lien could be foreclosed if the debt was not paid within six months, with priority given to the sale of unoccupied portions of the land.
Ratio:
- (Unlock)