Title
Manacop, Jr. vs. Cansino
Case
G.R. No. L-13971
Decision Date
Feb 27, 1961
Dispute over land ownership in Nueva Ecija; Cansino's prior registration and 30-year possession upheld, defeating Manacop's claim of good faith purchase.
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Case Digest (G.R. No. L-13971)

Facts:

Original Ownership and Transfers

  • The disputed land is located in sitio Mapaltoc, barrio of Paytan, municipality of Cuyapo, Nueva Ecija.
  • It was originally covered by Homestead Patent No. 235, issued to Sabina Tomas on October 15, 1914, and registered under Original Certificate of Title No. 144 on November 15, 1914.
  • Sabina Tomas sold portions of the land to Mr. and Mrs. Bartolome Ancheta (May 20, 1920, and October 30, 1922) and to Mr. and Mrs. Faustino Cansino (June 1, 1922, and May 29, 1923).
  • In cadastral proceedings, Lot No. 342 was adjudicated to the Anchetas, and Lot No. 387 to the Cansinos. Original Certificate of Title No. 4742 (Lot No. 387) was issued to the Cansinos on September 22, 1925, and Original Certificate of Title No. 3885 (Lot No. 342) to the Anchetas on August 21, 1925.
  • On March 28, 1937, the Anchetas sold Lot No. 342 to the Cansinos, who secured Transfer Certificate of Title No. 13591 on July 11, 1938.

Subsequent Transfers and Claims

  • Sabina Tomas died on June 15, 1952. Her children, Juliana and Clodualdo Dagdag, applied for a duplicate of Transfer Certificate of Title No. 99, which was issued on November 27, 1953.
  • On December 23, 1953, the Dagdag siblings executed a deed of extrajudicial partition, and Transfer Certificate of Title No. NT-14970 was issued in their name.
  • On November 28, 1955, the Dagdag siblings sold the land to Benito Bringas, who secured Transfer Certificate of Title No. NT-18797 on November 29, 1955.
  • On July 2, 1956, Benito Bringas assigned the land to Carlos Manacop, Jr., who obtained Transfer Certificate of Title No. NT-20508 on the same date.

Dispute and Legal Action

  • On March 5, 1957, Carlos Manacop, Jr. filed a complaint against Faustino Cansino, alleging ownership of the land under Transfer Certificate of Title No. NT-20508 and seeking possession, damages, and attorney's fees.
  • Cansino countered that he and his predecessors had acquired the land from Sabina Tomas and had been in continuous, peaceful, and exclusive possession for over 30 years. He sought dismissal of the complaint and damages.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Good Faith of Purchaser: A purchaser cannot claim good faith if they are aware of facts that would prompt a reasonably prudent person to inquire into the status of the property. Manacop admitted knowledge of Cansino's possession, negating his claim of good faith.
  2. Extrajudicial Settlements: The two-year period under Section 4, Rule 74 applies only to judicial settlements, not extrajudicial ones. In extrajudicial settlements, the ordinary prescriptive period applies.
  3. Superiority of Title: Continuous, peaceful, and exclusive possession for over 30 years, coupled with prior registration, establishes a stronger claim to ownership. Cansino's title, derived from Sabina Tomas and supported by prior registration, is superior to Manacop's title.


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