Title
Heirs of Macalalad vs. Rural Bank of Pola, Inc.
Case
G.R. No. 200899
Decision Date
Jun 20, 2018
The heirs of Paz Macalalad file a petition to nullify a Transfer Certificate of Title against Rural Bank of Pola, Inc., claiming that the bank acted in bad faith as a mortgagee and subsequent purchaser, but the Court affirms the decisions of the lower courts, recognizing the bank's status as a purchaser in good faith and imposing a fine on the bank's General Manager for non-compliance with court directives.
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Case Digest (G.R. No. 200899)

Facts:

  • The case involves the Heirs of Paz Macalalad (Marieta Macalalad, Arlene Macalalad-Aday, Jimmy Macalalad, Ma. Cristina Macalalad, Nenita Macalalad-Papa, and Danny Macalalad) as petitioners.
  • Respondents are the Rural Bank of Pola, Inc. and the Register of Deeds of Oriental Mindoro.
  • Petitioners sought to nullify Transfer Certificate of Title (TCT) No. T-117484, alleging the bank acted in bad faith as a mortgagee and subsequent purchaser.
  • The case originated from a complaint filed by Paz Macalalad on September 26, 2003, in the RTC of Calapan City, Oriental Mindoro, Branch 40, in Civil Case No. R-03-5244.
  • Paz claimed to be the sole surviving legal heir of Leopoldo Constantino, Jr., who owned land in Pinagsabangan II, Naujan, Oriental Mindoro.
  • After Leopoldo's death, it appeared that he sold the land to Spouses Remigio and Josephine Pimentel, who then mortgaged it to the respondent bank.
  • The Spouses Pimentel defaulted on their loan, leading to the foreclosure of the mortgage and the bank acquiring the property as the highest bidder.
  • The RTC dismissed the complaint, ruling that the bank acted in good faith.
  • The CA affirmed the RTC's decision.
  • Petitioners filed a petition for review on certiorari with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition for review on certiorari, affirming the decisions of the RTC and the CA.
  • The Court held that the respondent bank acted in good faith and was an innocent mortgagee for value.
  • The Court imposed an additional fine of P2,000.00 o...(Unlock)

Ratio:

  • The Supreme Court noted that the petitioners failed to implead the Spouses Pimentel, who were indispensable parties, in their complaint.
  • The Court reiterated the principle that no one can transfer a right greater than what they have, and a forged deed cannot be the root of a valid title unless an innocent purchaser for value intervenes.
  • Th...continue reading

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