Title
Register of Deeds of Negros Occidental vs. Anglo Sr.
Case
G.R. No. 171804
Decision Date
Aug 5, 2015
Respondents lost land due to fraudulent registration, sought damages from Assurance Fund. SC denied claim, citing negligence, lack of loss, and failure to meet statutory requirements under PD 1529.

Case Digest (A.C. No. 12876)
Expanded Legal Reasoning Model

Facts:

  • Background and Legislative Framework
    • The case involves the application of the Assurance Fund under Presidential Decree No. 1529, which provides recourse for losses sustained by persons relying on certificates of title issued under the Torrens system.
    • The Assurance Fund is intended to indemnify innocent purchasers who suffer damage or loss due to errors, omissions, misdescriptions, or fraud in the registration system, provided that the purchaser is not negligent.
  • Chronology of Events
    • June 29, 1960 – Alfredo V. de Ocampo filed an application before the Court of First Instance (CFI) of Negros Occidental to register two parcels of prime sugar land (Lot No. 2509 of the Escalante cadastral survey and Lot No. 817 of the Sagay cadastral survey).
    • The registration was contested by the Republic of the Philippines Bureau of Education on the ground that the lots had been bequeathed by the late Esteban Jalandoni and were evidenced by Transfer Certificate of Title (TCT) No. 6014.
    • June 15, 1962 – While the registration proceedings were pending, de Ocampo entered into a Deed of Conditional Sale with Oscar Anglo, Sr., whereby de Ocampo agreed to transfer Lot No. 2509 and a portion of Lot No. 817 under specified conditions.
    • August 3, 1965 – Branch IV of the CFI of Negros Occidental ordered the registration of the properties in favor of de Ocampo.
    • October 1, 1965 – Original Certificate of Title (OCT) No. 576-N covering both lots was issued in the name of de Ocampo.
    • December 28, 1965 – The Republic filed a Petition for Relief from Judgment challenging the decision awarding the title to de Ocampo.
    • January 6, 1966 – de Ocampo sold Lot No. 2509 and a portion of Lot No. 817 (designated Lot No. 817-D) to Oscar Anglo, Sr.; the sale was registered and later resulted in the cancellation of OCT No. 576-N and the issuance of TCT No. T-42217 in Anglo, Sr.’s favor.
    • March and August 1966 – The Republic caused the annotations of notices of lis pendens on the title covering the properties.
    • August 20, 1967 – The CFI in San Carlos City dismissed the Republic’s Petition; the decision was subsequently upheld by the Court of Appeals in August 1969.
    • May 17, 1976 – Despite the presence of lis pendens, Anglo, Sr. conveyed the lots (covered by TCT No. T-42217) to Anglo Agricultural Corporation in exchange for shares of stock, with the deed expressly noting that the adverse decision risk fell on the transferee.
    • May 19, 1976 – TCT No. T-42217 was cancelled and a new certificate of title (TCT No. T-88727) was issued in favor of Anglo Agricultural Corporation.
    • June 7, 1976 – The parties amended the conveyance agreement, whereby Anglo, Sr. expressly assumed all liabilities arising from any adverse decision, effectively altering his stance as an innocent purchaser.
    • Subsequent proceedings – The Court of Appeals in May 1978, and later in decisions rendered in 2005 and 2006, addressed the merits of the case including the conflicting titles between de Ocampo’s and the Bureau of Education’s certificates. Ultimately, the Court of Appeals reversed earlier rulings by declaring the certificate of title in de Ocampo’s favor null and void and confirming the Bureau of Education’s title (TCT No. 6014).
    • April 5, 1988 – Anglo, Sr. and Anglo Agricultural Corporation filed a Complaint for Recovery of Damages from the Assurance Fund against the Register of Deeds of Negros Occidental and the National Treasurer, asserting that they acquired the lots in good faith, for value, and without negligence, despite later adverse findings.
    • Trial and Appellate Proceedings – The Regional Trial Court awarded damages (computed based on fair market value) and attorney’s fees to the respondents. The Court of Appeals later affirmed the damages award but deleted the attorney’s fees component.
    • Final Stages – The Register of Deeds and the National Treasurer elevated the case to the Supreme Court on a Petition for Review on Certiorari, arguing that the respondents’ claims were barred because of negligence and risky business conduct.
  • Parties and Their Positions
    • Petitioners:
      • The Register of Deeds of Negros Occidental and the National Treasurer of the Republic of the Philippines.
      • Argued that the respondents (Anglo, Sr. and Anglo Agricultural Corporation) were not entitled to recover from the Assurance Fund because they purchased the properties with negligence or assumed risk knowingly.
    • Respondents:
      • Oscar Anglo, Sr. and Anglo Agricultural Corporation.
      • Claimed eligibility for compensation under Section 95 of PD No. 1529, asserting that they purchased the properties in good faith and for value, relying on a certificate of title free from adverse indications at the time of purchase.
  • Evidence Presented and Procedural Issues
    • Evidence from witnesses and documentary records indicated that at the time of the sale between de Ocampo and Anglo, Sr., the original certificate of title did not contain annotations of lis pendens.
    • Testimonies established that de Ocampo was in possession of the lots prior to the sale, and that subsequent adverse entries (including those made by the Republic) occurred after the transfer.
    • The procedural issue of whether de Ocampo should have been impleaded as a party in the suit was raised by petitioners, who maintained that such impleading was mandatory under Section 96 in relation to Section 97 of PD No. 1529.
    • The absence of any opposition or evidence from the Register of Deeds and the National Treasurer on the witnesses’ testimonies further complicated the admittance of the respondents’ claims.

Issues:

  • Whether respondents Oscar Anglo, Sr. and Anglo Agricultural Corporation are entitled to recover damages from the Assurance Fund under Section 95 of Presidential Decree No. 1529.
    • Did the respondents sustain loss or damage as a result of fraud, error, omission, or misdescription in the certificate of title or the registration process?
    • Was there any negligence on the part of the respondents that would preclude recovery from the Assurance Fund?
  • Whether the respondents were required to implead Alfredo de Ocampo (or his estate) in their complaint for recovery of damages from the Assurance Fund, and if his non-impleading should bar their claim.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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