Case Digest (G.R. No. 179543)
Facts:
The case involves Camper Realty Corporation as the petitioner and Maria Nena Pajo-Reyes, represented by her attorney-in-fact Eliseo B. Ballao, along with Augusto P. Bajado, Rodolfo Pajo, and Godofredo Pajo, Jr. as respondents. The events leading to the case began on March 27, 1974, when Rodolfo Pajo notarized a Special Power of Attorney (SPA) executed by himself and purportedly by his four siblings: Maria Nena Pajo-Reyes, Godofredo Pajo, Jr., Tito Pajo, and Isaias Pajo. This SPA authorized Rodolfo to sell a parcel of land located in Catalunan Pequeño, Davao City, covering an area of 8,060 square meters and registered under Transfer Certificate of Title (TCT) No. T-41086 in the names of the siblings. The day after the notarization, on March 28, 1974, Rodolfo sold the property to Ligaya Vda. De Bajado, who subsequently had the title canceled and a new title (TCT No. T-43326) issued in her name on April 1, 1974.
Two days after the notarization, Atty. Camilo Naraval, who notar...
Case Digest (G.R. No. 179543)
Facts:
Background of the Property and SPA
- Rodolfo Pajo caused the notarization of a Special Power of Attorney (SPA) on March 27, 1974, executed by him and purportedly by his siblings Maria Nena Pajo-Reyes (Nena), Godofredo Pajo, Jr., Tito Pajo, and Isaias Pajo. The SPA authorized Rodolfo to sell a parcel of land in Davao City, covered by Transfer Certificate of Title (TCT) No. T-41086.
Sale of the Property
- On March 28, 1974, Rodolfo sold the property to Ligaya Vda. de Bajado (Ligaya), who subsequently caused the cancellation of the original title and the issuance of TCT No. T-43326 in her name on April 1, 1974.
- Two days after notarizing the SPA, Atty. Camilo Naraval noticed that all signatures except Rodolfo’s were forged. He informed Rodolfo’s co-owners and canceled the SPA from his notarial register.
Transfer of Ownership
- After Ligaya’s death, the property was bequeathed to her son, Augusto Bajado, via a Partition Agreement dated June 14, 1985. TCT No. T-118270 was issued in Augusto’s name on July 16, 1986.
- In 1992, Augusto divided the property into two lots. He sold the larger portion (7,420 sqm) to Camper Realty Corporation (petitioner) on August 31, 1992, which was later covered by TCT No. 185958. Augusto retained the smaller portion (640 sqm), covered by TCT No. 185959.
Legal Proceedings
- On April 2, 1993, Nena filed a complaint against Augusto, Rodolfo, and Godofredo, Jr., seeking the nullity of contracts, cancellation of titles, and damages. She alleged that the SPA was forged and that only she and Godofredo, Jr. remained as co-owners.
- The Regional Trial Court (RTC) dismissed Nena’s complaint, finding her guilty of laches and upholding the validity of the transfers to Augusto and petitioner.
- The Court of Appeals (CA) reversed the RTC’s decision, declaring the SPA and subsequent transfers null and void. It ordered the cancellation of titles issued to Augusto and petitioner and the reinstatement of the original title (TCT No. T-41086).
Petitioner’s Appeal
- Petitioner filed a Motion for Reconsideration, claiming it did not receive the CA’s decision due to improper service. The CA denied the motion, prompting petitioner to file a petition for review before the Supreme Court.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Forgery and Validity of SPA: A forged document cannot transfer valid title. Since the SPA was forged, the subsequent sale to Ligaya was void, and no rights were transmitted to her or her heirs.
- Innocent Purchaser for Value: A purchaser in good faith who relies on a clean Torrens title is protected under the law. Petitioner had no knowledge of the forgery or any defect in Augusto’s title and was thus entitled to protection as an innocent purchaser.
- Laches: Laches does not apply when the plaintiff’s delay is justified, and there is no prejudice to the defendant. Nena’s delay in filing the complaint did not bar her from seeking relief.
- Legal Interest: The Court imposed a 6% legal interest on the reimbursement of the purchase price, consistent with the ruling in Eastern Shipping Lines v. Court of Appeals.
Dispositive Portion
- The Deed of Absolute Sale dated March 28, 1974, and TCT No. T-43326 are declared null and void.
- TCT No. 195213 in the name of Camper Realty Corporation is declared valid.
- Rodolfo Pajo is ordered to pay Nena moral damages, attorney’s fees, and exemplary damages.
- Augusto Bajado is ordered to return the purchase price to Nena and Godofredo, Jr., with 6% legal interest from the date of filing the complaint.
- The Register of Deeds is ordered to cancel TCT No. T-185959 in Augusto’s name and issue a new title in the names of Nena and Godofredo, Jr.