Case Digest (G.R. No. 153690)
Facts:
The case involves Enriqueta M. Locsin (petitioner), the registered owner of a 760-square meter lot situated at 49 Don Vicente Street, Don Antonio Heights Subdivision, Quezon City, covered by Transfer Certificate of Title (TCT) No. 235094. In 1992, Locsin filed an ejectment case against Billy Aceron to recover possession of the property. A compromise agreement was approved by the Metropolitan Trial Court (MTC) in 1993. Locsin then left for the United States but continued to pay real property taxes.
In 1994, upon discovering her copy of TCT No. 235094 was missing, Locsin filed a petition for administrative reconstruction, resulting in the issuance of a new certificate, TCT No. RT-97467. In 1999, Marylou Bolos allegedly obtained a new TCT No. N-200074, claiming ownership of the property via a Deed of Absolute Sale dated November 3, 1979, purportedly signed by Locsin. Bolos subsequently sold the property to Bernardo Hizon, who registered it under his son Carlos Hizon's name. Ca
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Case Digest (G.R. No. 153690)
Facts:
- Parties and Property
- Petitioner Enriqueta M. Locsin was the registered owner of a 760-sq.m. lot located at 49 Don Vicente St., Don Antonio Heights Subdivision, Barangay Holy Spirit, Capitol, Quezon City, covered by Transfer Certificate of Title (TCT) No. 235094.
- Respondents include Bernardo Hizon, Carlos Hizon (Bernardo’s son), Spouses Jose Manuel and Lourdes Guevara.
- Legal Proceedings and Transactions
- In 1992, Locsin filed an ejectment case (Civil Case No. 38-6633) against a certain Billy Aceron for recovery of possession over the lot. A compromise agreement was approved by the Metropolitan Trial Court (MTC) on August 6, 1993.
- Locsin went to the United States after the compromise, continued paying real property taxes, but did not monitor compliance by Aceron.
- In 1994, Locsin’s copy of TCT No. 235094 went missing; she filed for administrative reconstruction and obtained TCT No. RT-97467.
- In 1999, Marylou Bolos succeeded in having TCT No. RT-97467 canceled and secured TCT No. N-200074 in her favor by registering a Deed of Absolute Sale dated November 3, 1979, allegedly executed by Locsin.
- Bolos sold the property to Bernardo Hizon for PHP 1.5 million; however, the title was transferred to Carlos Hizon on August 12, 1999.
- On October 1, 1999, Bernardo filed a Motion for Issuance of Writ of Execution to enforce the compromise agreement.
- In 2002, Locsin’s counsel discovered the transactions and challenged the legitimacy of the Deed of Absolute Sale, alleging Locsin’s signature on it was forged.
- Locsin’s letter dated May 9, 2002, requested the return of the property; Carlos denied knowledge of any defects and claimed innocence as purchaser in good faith.
- On July 15, 2002, Locsin learned that Carlos had sold the property to the spouses Guevara, who had a new title (TCT No. N-237083) issued on May 24, 2002.
- The spouses Guevara mortgaged the property to Damar Credit Corporation (DCC), but the mortgage was later canceled because the loan was never availed of.
- Locsin filed an action for reconveyance, annulment of the title in favor of the spouses Guevara, cancellation of the mortgage lien, and damages against all parties including Bolos, the Hizons, the spouses Guevara, and DCC (Civil Case No. Q-02-47925). Charges against DCC were later dropped.
- Decisions by Lower Courts
- The Regional Trial Court (RTC) dismissed Locsin’s complaint, holding:
- Insufficient evidence to prove forgery of Locsin’s signature on the deed to Bolos;
- The deed was a notarized public document and presumed regular;
- Transfers from Bolos to Carlos and from Carlos to the spouses Guevara were valid;
- Respondents were innocent purchasers for value and in good faith.
- Petitioner appealed to the Court of Appeals (CA).
- The CA ruled that Locsin did prove forgery of her signature but nevertheless affirmed respondents’ status as innocent purchasers for value under the Torrens System’s policy of characterizing the certificate of title as conclusive evidence of ownership. The CA cited the rule that only knowledge of suspicious or defective title facts would require a purchaser to investigate further.
- Petition Before the Supreme Court
- Petitioner argues that respondents had knowledge or should have been aware of the defects or dispute involving the property due to the ejectment case and compromise agreement.
- Petitioner contests the bona fide nature of the sale to the spouses Guevara, alleging simulation intended to keep the property out of her reach.
- Respondents maintain they are innocent purchasers who relied solely on the certificates of title, which were free from liens or encumbrances, and that possession by Aceron does not establish bad faith.
Issues:
- Whether respondents are innocent purchasers for value and in good faith despite the forged deed and irregular transfers involving the subject property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)