G.R. No. 92163 - Enrile vs. Salazar

Plaintiffs: Leonida Mari and Caridad Evangelista.
Defendants: Isaac Bonilla and Silvina Ordanez.
The subject property is a parcel of land consisting of 7.0652 hectares registered under Original Certificate of Title No. 4905, located at Valdefuente, Cabanatuan, Nueva Ecija.
This property is a homestead patent acquired on January 23, 1935.

Casimiro Evangelista, the registered owner of the land, was married to Leonida Mari on February 7, 1920.
Their marriage produced two children: Caridad Evangelista and Deogracias Evangelista.
Casimiro Evangelista died intestate around 1938, leaving unresolved questions regarding the heirs’ rights.

On January 10, 1944, Deogracias Evangelista, claiming to be the sole heir of Casimiro Evangelista, executed a declaration of heirship (Doc. No. 9, Page 30, Book No. 18) before a notary.
On the same day, Deogracias sold the subject property to defendants for the sum of P2,400, as evidenced in Doc. 10, Page No. 31, Book No. 18.
The transaction was executed despite Deogracias not being the registered owner, as the land was still registered in the name of Casimiro Evangelista.

Immediately following the sale, the original Certificate of Title No. 4905 was cancelled.
Subsequently, a Transfer Certificate of Title No. 19991 was issued in the names of the defendants, Isaac Bonilla and Silvina Ordanez.

After the sale, defendants assumed possession of the land.
The land was actively cultivated: the harvest for 1944–1945 amounted to seventeen cavanes, and portions were planted with palay, sugar cane, and camoting kahoy.
Defendants had come to reside in Platero, Cabanatuan by March 1938, whereas the plaintiffs had been residing there since 1920.

Defendants were aware that Leonida Mari was the mother of Deogracias Evangelista.
They knew that Deogracias was living with his grandfather, Matias Evangelista, while Caridad resided with her mother.
An agreement allowed for further submission of memoranda on legal points by both parties to clarify facts and issues within a set period.

The trial court rendered judgment in favor of the plaintiffs without awarding costs.
Defendants appealed on the ground of good faith in their purchase, citing precedents including Castillo vs. Valdez to reinforce their position.

Whether the defendants, as purchasers for value, may invoke the protection of good faith under the Torrens system despite purchasing from a vendor (Deogracias Evangelista) who was not the registered owner.

The issue interrogates the applicability of the doctrine of indefeasibility when the vendor’s title does not reflect true ownership.

Whether the cancellation of the original certificate and the subsequent issuance of a new title in the defendants’ names validly transfers ownership under the doctrines governing the Torrens system.

It examines if relying solely on the new certificate negates the need for further inquiry into the vendor's right to convey the title.

Whether the defendants’ reliance on a judicial settlement (under Rule 74) that adjudicated Deogracias Evangelista as having the entire estate protects them against claims of the co-heirs.

The inquiry focuses on whether a summary settlement relying on a self-serving affidavit can bar subsequent claims of rightful heirs.