Case Digest (G.R. No. L-17951)
Facts:
In Conrado C. Fule and Lourdes E. Aragon v. Emilia E. de Legare and Court of Appeals (G.R. No. L-17951, February 28, 1963), Emilia E. de Legare owned a house and lot at No. 146 Sta. Mesa Boulevard Extension, San Juan, Rizal, evidenced by Transfer Certificate of Title (TCT) No. 21253. On September 26, 1951, she mortgaged the property to secure an ₱8,000 loan from Tomas Q. Soriano, later reduced to ₱7,000. On the night of March 29, 1953, her adopted son, John W. Legare, coercively obtained her signature on a document purported to be a U.S. Veterans Administration claim but in fact a deed of sale in his favor. He then hid his mother and her maid for over a month and sold the property through a licensed broker, Elias B. Fermin, to petitioners Conrado C. Fule and Lourdes E. Aragon for ₱12,000, who agreed to assume the ₱7,000 mortgage. Both conveyances were duly registered, producing TCT Nos. 30126 and 30127. Upon Emilia’s return, she found her property occupied and her possessions goCase Digest (G.R. No. L-17951)
Facts:
- Ownership and Encumbrance
- Emilia E. de Legare owned a house and lot at No. 146 Sta. Mesa Boulevard Extension, San Juan, Rizal (TCT No. 21253), and lived there with her adopted son John W. Legare and maid Purita Tarrosa.
- On September 26, 1951, she mortgaged the property to Tomas Q. Soriano for ₱8,000 (first-class mortgage, recorded). By February 23, 1953, the debt was reduced to ₱7,000 but not annotated on the title.
- Fraudulent Conveyance to Adopted Son
- On March 29, 1953, an intruder threatened Emilia for ₱10,000. After he left, John induced Emilia and Purita to sign a paper he claimed was a U.S. Veterans Administration application. It was actually a deed of sale conveying the property to John for ₱12,000, acknowledged April 7, 1953.
- Emilia and Purita hid at the Windsor Hotel until May 7–8, 1953. Upon return, they found strangers in the house and learned of the fraudulent sale.
- Sale to the Petitioners (Fule & Aragon)
- Broker Elias B. Fermin arranged sale to spouses Conrado C. Fule and Lourdes E. Aragon for ₱12,000, with the ₱7,000 mortgage assumed by the buyers. On May 9, 1953, Soriano sold the property to the spouses, who then mortgaged it back to him for ₱7,000.
- The Register of Deeds recorded:
- The deed of Emilia → John, issuing TCT No. 30126.
- The deed of John → Fule & Aragon, issuing TCT No. 30127.
- The mortgage to Soriano.
- After registration, the spouses paid the balance of the purchase price (≈₱4,000).
- Proceedings Below
- Trial Court ordered cancellation of TCT Nos. 30126 & 30127, reinstated TCT No. 21253 with Soriano’s mortgage, delivered possession to Emilia, awarded damages, attorney’s fees, and cross-claim relief.
- Court of Appeals modified: revived TCT No. 21253 with reduced ₱7,000 mortgage annotation; eliminated attorney’s fees against Fule & Aragon; affirmed other relief.
Issues:
- Were spouses Fule and Aragon purchasers in good faith and for value of the property?
- Does registration under the Torrens system render a fraudulent deed a valid root of title for subsequent purchasers?
- Does Article 1434, Civil Code, vest title in an innocent purchaser when a non-owner vendor later acquires registered title?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)