Facts:

• A dispute over the ownership of a parcel of land in the Philippines.
• On February 8, 1916, a Torrens certificate of title was issued in favor of Juana Angeles and seventeen others as tenants in common.
• On April 29, 1921, a deed purporting to be executed by eleven of the persons in interest in said land and conveying about 47 hectares of the land to Pedro Manuntag was presented to the register of deeds.
• The deed was later discovered to be a forgery.
• Pedro Manuntag mortgaged the property to Soledad P. Hernandez, and the mortgage was noted on the owner's duplicate of the original certificate of title.
• Soledad P. Hernandez acquired the property through an absolute deed of conveyance from Pedro Manuntag.
• A cadastral proceeding was initiated by the Director of Lands, and the Angeles heirs appeared as claimants.
• Soledad P. Hernandez claimed ownership of the property based on her purchase from Pedro Manuntag.
• The court denied her motion to issue a certificate of title in her name, but after further proceedings, the court decided in favor of Soledad P. Hernandez.

Issue:

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Ruling:

• Soledad P. Hernandez did not acquire valid title t...(Unlock)

Ratio:

• The principle that a forged deed is a nullity and conveys no title is firmly established in Philippine jurisprudence.
• Under the Torrens registration system, the act of registration is the operative act to convey and affect the land.
• The entry of a mere memorandum of a conveyance in fee simple upon the original certificate of title without the issuance of a transfer certificate of title to the purchaser is not a sufficient registration of the conveyance.
• The issuance of a transfer certificate of title to the purchaser is one of the essential features of a conveyance in fee by registration.
• In order to enjoy the full protection of the registration system, the purchaser must be a holder in good faith o...continue reading