Case Digest (G.R. No. 205271)
Facts:
Land Bank of the Philippines v. Belle Corporation, G.R. No. 205271, September 02, 2015, Supreme Court Third Division, Peralta, J., writing for the Court.Petitioner Land Bank of the Philippines (petitioner or Land Bank) sought review under Rule 45 of the Court of Appeals' (CA) November 23, 2011 Decision and January 17, 2013 Resolution in CA‑G.R. CV No. 84075 which had annulled the Regional Trial Court (RTC), Branch 18, Tagaytay City's April 12, 2004 Decision in Civil Case No. TG‑1672. Respondent Belle Corporation (respondent or Belle) had originally sued Florosa A. Bautista (Bautista) and the Register of Deeds of Tagaytay City on November 20, 1996 for quieting of title and damages, seeking injunctions to protect its possession over consolidated parcels covered by TCT Nos. P‑1863 to P‑1866.
Belle alleged its title derived from early OCTs (notably OCT No. 0‑216 and OCT No. 55) and described how consolidation, subdivision and mergers produced TCT Nos. P‑1863 to P‑1867 registered December 12, 1995; it accused Bautista of posting a sign and claiming part of Belle’s access road as falling within her TCT No. P‑671 (derived from OCT OP‑283 via a 1977 free patent). Bautista counterclaimed and relied on a DENR verification survey, commissioned jointly by the parties, which concluded — by reference to mother‑title registration dates entered on the face of titles — that Bautista’s title had precedence over Belle’s for the overlapping portion.
During trial, Belle moved to implead Land Bank as indispensable after learning Bautista had mortgaged TCT No. P‑671 to Land Bank and that a foreclosure and issuance of TCT No. P‑3663 in Land Bank’s name had occurred; the RTC granted leave and Land Bank filed an answer, counterclaim and third‑party complaint against Liezel’s Garments, Inc. Land Bank claimed to be an innocent mortgagee for value who had verified the mortgaged title and conducted inspections; it sought recovery against Bautista and Liezel’s Garments, Inc. for unpaid indebtedness.
The RTC (April 12, 2004) declared void the 7,693 sq. m. portion of TCT No. P‑1863 that overlapped TCT No. P‑671 and ordered cancellation of that portion from P‑1863. On appeal, the CA (Nov. 23, 2011; mod. Jan. 17, 2013) annulled the RTC, declared Belle the owner of the disputed property, voided TCT No. P‑671 (and derivative TCT No. P‑3663) ab initio insofar as the overlapping 7,693 sq. m. was concerned, ordered cancellation/correction of the relevant titles, directed Bautista and Liezel’s Garments, Inc. to jointly pay Land Bank P16,327,991.40 (the foreclosure sale price), and awarded Belle P100,000 for attorney’s fees. Land Bank moved for reconsideration which the CA denied.
Land Bank then filed this Rule...(Pro-only)
Issues:
- Did the Court of Appeals err in holding that Belle Corporation was not bound by the findings of the expert (DENR) who conducted the joint verification survey of the disputed property?
- Did the Court of Appeals err in failing to apply Section 44, Rule 130 of the Rules of Court (entries in official records) to the title covering the disputed property?
- Was Land Bank of the Philippines a mortgagee in good faith and for value?
- Was the award of attorney’s fees...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)