G.R. No. 185215 - Bautista vs. Civil Service Commission

Petitioner Land Bank of the Philippines is a banking institution duly organized under Philippine laws.
Respondent Barbara Sampaga Poblete is the registered owner of Lot No. 29, a 455-square meter parcel located in Buenavista, Sablayan, Occidental Mindoro, under OCT No. P-12026.

In October 1997, Poblete secured a loan in the amount of P300,000.00 from Kabalikat ng Pamayanan ng Nagnanais Tumulong at Yumaman Multi-Purpose Cooperative (Kapantay) and used Lot No. 29 as collateral.
Kapantay subsequently used the same title (OCT No. P-12026) as collateral for its own loan account (No. 97-CC-013) with Land Bank-Sablayan Branch.

In November 1998, Poblete, seeking to settle her loan, instructed her son-in-law Domingo Balen to find a buyer for Lot No. 29.
Angelito Joseph Maniego was referred to Poblete and agreed to purchase the property for P900,000.00, though he suggested preparing a deed of sale for P300,000.00 to lower taxes.
Accordingly, Poblete executed a Deed of Absolute Sale on 9 November 1998 for the lower consideration; however, Balen later testified that despite delivering the deed, the full purchase price was never received as Maniego postponed payment pending his return from the United States.
Subsequent to these transactions, Maniego used the Deed dated 9 November 1998, indirectly through its impact on title evolution, to effect further dealings with Land Bank.

On 8 June 2000, Maniego applied for a P1,000,000.00 loan with Land Bank, offering OCT No. P-12026 as collateral.
As a condition for the loan approval, Land Bank required the title to be transferred to Maniego.
On 14 August 2000, a Deed of Absolute Sale (dated 11 August 2000) was executed, and the Register of Deeds of Occidental Mindoro issued Transfer Certificate of Title (TCT) No. T-20151 in Maniego’s name.
On 15 August 2000, a Credit Line Agreement and a Real Estate Mortgage were executed between Maniego and Land Bank, leading to the release of the loan proceeds.

Maniego later defaulted on his loan repayment, prompting Land Bank on 4 November 2002 to file an Application for Extra-judicial Foreclosure of the Real Estate Mortgage based on the outstanding indebtedness.
On 2 December 2002, Poblete initiated a Complaint for Nullification of the Deed dated 11 August 2000, the reconveyance of title, and damages, alleging:

Non-payment of the agreed purchase price (P900,000.00) linked to the deed sale.
That the deed used for the title transfer bore forged signatures of her and her deceased husband (Primo Poblete).
The assertion was supported by documentary evidence such as a death certificate and an NBI report identifying the alleged forgeries.

The RTC of San Jose, Occidental Mindoro, Branch 46 issued a Decision on 28 December 2007 ruling in favor of Poblete:

Declaring the Deed dated 11 August 2000 and the resultant TCT No. T-20151 null and void due to forgery and lack of valid consideration.
Granting a permanent injunction against the foreclosure proceedings.
Ordering Maniego to return OCT No. P-12026 and pay reasonable attorney’s fees.

Land Bank, while asserting its cross-claim against Maniego for the unpaid loan, challenged the RTC’s ruling, as did Maniego.
The Court of Appeals (CA) affirmed in toto the RTC’s Decision on 28 September 2010, with subsequent motions for reconsideration denied.

Whether the Court of Appeals erred in upholding the trial court’s finding that TCT No. T-20151 is null and void.
Whether the CA misappreciated the evidence by not recognizing the title registration in Maniego’s name as valid.
Whether the CA misconstrued the evidence regarding Land Bank’s status as a mortgagee in good faith.
Whether the CA erred in not finding that Poblete and Maniego were in pari delicto with respect to their roles in the transaction.
Whether the CA misapplied the doctrines of estoppel and laches by not considering Poblete’s negligence in safeguarding her property rights.