Title
Republic vs. Umali
Case
G.R. No. 80687
Decision Date
Apr 10, 1989
Land in Tanza, Cavite, transferred via forged affidavit; subsequent innocent purchasers' titles upheld under Torrens system, barring government reversion.
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Case Digest (G.R. No. 80687)

Facts:

  1. Origins of the Land: The land in question, located in Tanza, Cavite, consists of 78,865 square meters. It was originally purchased on installment from the government on July 1, 1910, by Florentina Bobadilla.
  2. Transfer of Rights: In 1922, Bobadilla allegedly transferred her rights to Martina, Tomasa, Gregorio, and Julio Cenizal. Later, Tomasa and Julio assigned their shares to Martina, Maria, and Gregorio Cenizal.
  3. Forged Affidavit: In 1971, a joint affidavit was purportedly signed by Maria, Gregorio, and Martina Cenizal, claiming full payment for the land. This affidavit was used to secure Deed No. V-10910 (Sale Certificate No. 1280) from the Secretary of Agriculture and Natural Resources on September 10, 1971.
  4. Issuance of Title: On October 13, 1971, TCT No. 55044 was issued in favor of Maria Cenizal, Gregorio Cenizal, and Rosalina, Luz, and Enrique Naval (in lieu of Martina Cenizal).
  5. Subsequent Transfers: By 1985, the land had been transferred multiple times, with Remedios Miclat, Juan C. Pulido, and Rosalina, Luz, and Enrique Naval holding titles under TCT Nos. 80392, 80393, and 80394, respectively.
  6. Government’s Claim: The government filed a complaint for reversion on October 10, 1985, alleging that the joint affidavit was forged, as Gregorio and Maria Cenizal had died in 1943 and 1959, respectively, and could not have signed the affidavit in 1971.

Issue:

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Ruling:

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Ratio:

  1. Protection of Innocent Purchasers: Under Section 39 of the Land Registration Act (now Section 44 of P.D. 1529), a certificate of title issued to an innocent purchaser for value is conclusive and indefeasible, even if the original title was tainted by fraud.
  2. Torrens System’s Purpose: The Torrens system aims to provide certainty and stability to land titles. Once a title is registered, it is protected against all claims, except those noted on the certificate or arising after registration.
  3. Fraud and Voidability: A title obtained through fraud is not automatically void ab initio but is voidable. If the land has passed to an innocent purchaser for value, the title becomes indefeasible.
  4. Prescription and Laches: The government’s action for reversion is barred by prescription and laches, as the land had been registered and transferred multiple times over several decades.
  5. Res Judicata: While not directly applicable, previous cases involving the same land and parties suggest that the issue of ownership has long been settled, and further litigation is unwarranted.


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