Title
Honorata Betia, Vicente Betia, Antonio Betia, Virgilia Betia, Nestora Betia, Francisco Betia, Jr., and Francisco Betia vs. Leonardo Gabito, Claudio Poscabol and the Court of Appeals
Case
G.R. No. L-7677
Decision Date
Feb 18, 1956
Land dispute over Torrens-registered property; unregistered private transfer document challenged by innocent purchaser for value; Supreme Court upheld title, ruling negligence barred defendants' claim.
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Case Digest (G.R. No. L-7677)

Facts:

Ownership and Transfer of Land:

  1. The case involves two portions of land in barrio Salvacion, Buenavista, Iloilo, originally owned by Dalmacia Natividad, covered by Original Certificate of Title No. 365 issued on November 6, 1914.
  2. Dalmacia Natividad bequeathed one-half of the land to Paulina Aungon and the other half to the children of her nephew Jose Maria Igpuara (Ramon, Jose Carmelo, and Luis) in a testament executed on September 27, 1919.
  3. Upon Dalmacia's death, the properties were adjudicated to the devisees, and Transfer Certificate of Title No. 1128 was issued on September 7, 1920, in their names pro indiviso.
  4. The Igpuaras' portion was later sold to Filomena Fernandez and Concepcion Ferrer, and Transfer Certificate of Title No. 2459 was issued on August 8, 1947, inscribing the land in their names and Paulina Aungon's name pro indiviso.
  5. On June 10, 1948, Filomena and Concepcion sold their shares to Paulina Aungon, making her the sole owner. Transfer Certificate of Title No. T-4335 was issued on June 11, 1948.
  6. Paulina Aungon died on May 27, 1950, and was succeeded by her children and husband, the petitioners.

Defendants' Claim: 7. Defendants Claudio Poscabol and Leonardo Gabito took possession of portions of the land in 1944 and 1946, claiming ownership by purchase from Eufemia Gallego's heirs, Florentin Gabiason and Evarista Gabiason. 8. They alleged that the portions were erroneously included in Dalmacia Natividad's survey and that Dalmacia executed a private document on May 15, 1919, conveying the portions to Florentin and Evarista for P40.00. However, the document was not notarized.

Trial Court Decision: 9. The trial court ruled in favor of the plaintiffs, declaring them the exclusive owners of the land and ordering the defendants to return the land and pay damages.

Court of Appeals Decision: 10. The Court of Appeals reversed the trial court's decision, declaring the defendants as owners of the land and dismissing the complaint, based on the private transfer document and the alleged bad faith of Paulina Aungon.

Issue:

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Ruling:

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Ratio:

  1. Innocent Purchaser for Value: Under Section 39 of Act 496 (Land Registration Act), a Torrens title issued to an innocent purchaser for value is indefeasible and prevails over unregistered claims. Paulina Aungon acquired the land in good faith and for value, and her title is protected by law.
  2. Bad Faith Not Proven: Bad faith cannot be presumed and must be proven by clear and positive evidence. The defendants failed to establish that Paulina Aungon knew of their adverse claim at the time of purchase.
  3. Negligence of Defendants: The defendants' failure to take legal steps to protect their claim, such as converting the private document into a public instrument or asserting their rights during probate proceedings, constitutes negligence. Their inaction allowed prescription to set in, barring their ownership claim.


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