Case Digest (G.R. No. L-25147)
Facts:
- The case Maquiling v. Umadhay (G.R. No. L-25147) was decided by the Supreme Court of the Philippines on May 29, 1970.
- Angelina Maquiling, through her guardian ad litem Carlos Maquiling, contested ownership of Lot 3092 in the Cadastral Survey of Jaro, Iloilo.
- The land was co-owned by seven individuals, including Paz Maquiling, who obtained her share from Maria Maquiling.
- After Paz's death in 1928, her children, including Enrique Gumban, inherited her share.
- On February 28, 1947, Enrique sold his one-third share to Angelina Maquiling for P400, but this transaction was not registered.
- Eriberto Gumban, Jr. claimed to be the sole heir and executed a deed of mortgage over the entire 2/7 share in favor of Monserrat Umadhay.
- The mortgage was registered, and after non-redemption, the property was sold at public auction to Umadhay, who later sold it to Crisanta S. Gumban.
- The trial court initially ruled in favor of Angelina Maquiling, but the Court of Appeals reversed this decision, validating the mortgage and sale.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Umadhay spouses could not claim protection under the theory of indefeasibility of Torrens title due to reliance on a mortgage executed by a non-registered owner.
- The Court affirmed that Crisanta S. Gumban w...(Unlock)
Ratio:
- The Court stated that the Umadhay spouses could not invoke the indefeasibility of Torrens title because the registered owner at the time of the mortgage was still Paz Maquiling.
- They relied on a self-serving affidavit from Eriberto Gumban, Jr., which did not establish ownership.
- Good faith protection is reserved for purchasers from the registered owner; since the Umadhays' transferor was ...continue reading
Case Digest (G.R. No. L-25147)
Facts:
The case of Maquiling v. Umadhay (G.R. No. L-25147) was decided by the Supreme Court of the Philippines on May 29, 1970. The petitioner, Angelina Maquiling, represented by her guardian ad litem Carlos Maquiling, contested the ownership of a parcel of land designated as Lot 3092 in the Cadastral Survey of Jaro, Iloilo. The land was originally co-owned by seven individuals, including Paz Maquiling, who acquired her share from Maria Maquiling. Following Paz's death in 1928, her children, including Enrique Gumban, inherited her share. On February 28, 1947, Enrique sold his one-third share of the property to Angelina Maquiling for P400; however, this transaction was not registered. Subsequently, Enrique’s brother, Eriberto Gumban, Jr., claimed to be the sole heir of their mother and executed a deed of mortgage over the entire 2/7 share of the property in favor of Monserrat Umadhay. This mortgage was duly registered, and after the failure to redeem the property, it was sold at public auction to Umadhay, who later sold it to Crisanta S. Gumban. The trial court initially ruled in favor of Angelina Maquiling, declaring her ownership of the one-third share. However, the Court of Appeals reversed this decision, upholding the validity of the mortgag...