Title
Mirasol vs. Gerochi y Gamboa
Case
G.R. No. L-4929
Decision Date
Jul 23, 1953
Heirs contested fraudulent land sales; court upheld partial validity, ruled annotations insufficient for ownership transfer under Torrens system, denying buyer's good faith claim.
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Case Digest (G.R. No. L-4929)

Facts:

Background of the Property

  • Lot No. 3760 of the cadastral survey of Iloilo City is the subject property, covered by Original Certificate of Title No. 1399.
  • The property was originally owned by Dionisia Gamboa and Teodorica Gamboa, each holding an undivided one-fourth (1/4) share.

Execution of Deeds of Sale

  • On July 30, 1946, two deeds of sale were executed:
    1. Filomeno Ledesma, posing as the sole heir of Teodorica Gamboa, sold her one-fourth undivided share to Salvador Solano.
    2. Saturnina Gerochi, posing as the sole heir of Dionisia Gamboa, sold her one-fourth undivided share to Salvador Solano.
  • These deeds were annotated on the original and duplicate certificates of title.

Subsequent Transactions

  • On August 1, 1946, Salvador Solano sold the portion acquired from Saturnina Gerochi to Natividad Escarrilla under a pacto de retro for P3,500.
  • On August 17, 1946, Solano sold the portion acquired from Filomeno Ledesma to Escarrilla for P1,400, later increased to P3,150.
  • These transactions were also annotated on the certificates of title.

Transfer to Antonio Mirasol

  • On October 21, 1946, Natividad Escarrilla transferred her interest in one-half of the undivided one-fourth share (originally from Saturnina Gerochi) to Antonio Mirasol for P3,150.
  • This deed of sale was annotated on the certificates of title.

Legal Action by Heirs

  • On October 8, 1947, Porfirio Gerochi, Mariano Gerochi, Juan Navajas, and Saturnina Navajas filed a case to annul the deeds of sale, claiming:
    1. Porfirio and Mariano Gerochi were the rightful heirs of Teodorica Gamboa.
    2. Saturnina and Juan Navajas were the rightful heirs of Dionisia Gamboa.
  • They sought to declare the deeds null and void and to be recognized as owners of the respective shares.

Lower Court Decision

  • The Court of First Instance dismissed the complaint, ruling that:
    1. Mariano Gerochi and Saturnina Navajas were estopped from seeking annulment as they had executed the deeds.
    2. Porfirio Gerochi and Juan Navajas’ remedy lay under Rule 74 of the Rules of Court.

Court of Appeals Decision

  • The Court of Appeals modified the lower court’s decision:
    1. Declared Antonio Mirasol the owner of Saturnina Navajas’ one-half share of the undivided one-fourth portion.
    2. Declared the deeds involving Filomeno Ledesma null and void.
    3. Recognized Porfirio and Mariano Gerochi as owners of Teodorica Gamboa’s one-fourth share.
    4. Recognized Juan Navajas as owner of one-half of Dionisia Gamboa’s one-fourth share.
    5. Ordered Natividad Escarrilla to pay Antonio Mirasol P1,575.

Issue:

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Ruling:

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Ratio:

  1. Protection Under the Torrens System: A purchaser of registered land must obtain a new certificate of title to enjoy the full protection of the Torrens system. Mere annotation of the deed of sale on the existing certificate is insufficient.
  2. Good Faith and Value: Antonio Mirasol cannot claim protection as a purchaser in good faith because he bought the property from Natividad Escarrilla, who did not have a certificate of title in her name.
  3. Chain of Title: The issuance of a transfer certificate of title is essential for a valid conveyance of registered land. Without it, the purchaser cannot claim protection under the Torrens system.
  4. Doctrine of Indefeasibility: The doctrine of indefeasibility of a Torrens title applies only to holders of a valid certificate of title. Mirasol, not being a holder of such a title, cannot invoke this doctrine.


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