Case Digest (G.R. No. 150224)
Facts:
In Spouses Alfonso and Maria Angeles Cusi (G.R. No. 195825) and Ramona Liza L. De Vera (G.R. No. 195871) versus Lilia V. Domingo, the contested property is a vacant, unfenced 658-square-meter lot in White Plains, Quezon City, covered by Transfer Certificate of Title (TCT) No. N-165606 in the name of Domingo. In July 1999, Domingo discovered unauthorized construction on her land and exposed a fraudulent chain of transactions. On July 18, 1997, Radelia Sy falsely represented herself as owner of the lot and secured from the Regional Trial Court (RTC) a duplicate owner’s copy of Domingo’s title by submitting a forged deed of absolute sale and an affidavit of loss. The Registry of Deeds then issued TCT No. 186142 in Sy’s name, which Sy subdivided and sold by contract to sell to Spouses De Vera and Spouses Cusi at P1,000,000 per half—far below the property’s market value of at least P14,000,000. RTC TCT Nos. 189568 and 189569 were issued in favor of the De Veras and Cusis, respectivelCase Digest (G.R. No. 150224)
Facts:
- Parties and Property
- Lilia V. Domingo was the registered owner of a 658 sqm vacant, unfenced lot in White Plains, Quezon City, covered by Transfer Certificate of Title (TCT) No. N-165606.
- Radelia Sy, representing herself as owner, procured by fraud a new owner’s duplicate of TCT No. N-165606 in July–August 1997.
- Anomalous Transactions by Sy
- July 14–18, 1997 – Sy submitted to the RTC: (a) a forged deed of absolute sale purportedly from Domingo; (b) an affidavit of loss of the original owner’s copy; and (c) petitioned for issuance of a duplicate title.
- August 26, 1997 – RTC granted her petition; Registry of Deeds issued TCT No. 186142 in Sy’s name.
- Sy subdivided the lot into two parcels and sold each half by contract to sell to Spouses Alfonso & Maria Angeles Cusi and Spouses Edgardo & Ramona Liza De Vera at P1,000,000 per half (actual market value ~P7,000,000 per half). Annotations of these contracts appeared on the dorsal of TCT No. 186142.
- Sy’s title was subsequently cancelled and re-issued as TCT No. 189568 in favor of the De Veras and TCT No. 189569 in favor of the Cusis.
- Procedural History
- Domingo filed Civil Case No. Q-99-39312 in the RTC for cancellation of titles, injunction, and damages. The RTC issued a TRO and preliminary injunction.
- September 30, 2003 – RTC Decision: voided sale to Sy, declared the Cusis and De Veras as purchasers in good faith and for value, awarded Sy’s liability for damages.
- October 2003 – On motions for reconsideration, RTC set aside its September 2003 decision, allowed further evidence.
- March 1, 2007 – RTC New Decision: (a) sale to Sy void ab initio; (b) Cusis and De Veras not purchasers in good faith and for value; (c) cancelled TCT Nos. 189568/189569; (d) revalidated Domingo’s TCT No. N-165606; (e) awarded Domingo moral, exemplary damages, attorney’s fees, litigation expenses, costs.
- July 16, 2010 – Court of Appeals (CA) in CA-G.R. CV No. 90452 affirmed the RTC’s March 2007 decision with modification of damages against the Sys.
- Cusis (G.R. No. 195825) and De Vera (G.R. No. 195871) filed petitions for review on certiorari before the Supreme Court.
Issues:
- Whether TCT No. 186142 issued to Sy is a reconstituted title (owner’s duplicate akin to reconstituted certificate).
- Whether the Cusis and De Veras are purchasers in good faith and for value under the Torrens system.
- (Cusis only) Whether petitioners are entitled to reimbursement of payments made plus damages and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)