Case Digest (G.R. No. 74070-71)
Facts:
In Sunshine Finance and Investment Corporation v. Intermediate Appellate Court and Rodolfo Rubidizo and Alfredo de Guzman, the petitioner, Sunshine Finance and Investment Corporation, sought to be recognized as an innocent purchaser for value of a 222-square-meter parcel of land in Pasig City covered by Original Certificate of Title No. 114 in the name of Benito Vega. On March 26, 1980, Vega’s vendee-mortgagors, spouses Romeo Nolasco and Erlinda de Belen, received Transfer Certificate of Title No. 22198. With their failure to repay a ₱52,466.34 loan, Sunshine foreclosed the mortgage, bought the property at public auction, and had Certificate of Sale annotated on TCT No. 22198. On May 26, 1982, TCT No. 37772 issued in Sunshine’s name. Sunshine then secured a writ of possession from the Regional Trial Court of Rizal in LRC Case No. R-3205 (June 20, 1983). On August 23, 1983, respondents Rubidizo and De Guzman filed a third-party claim in that case and a separate Civil Case No. 501Case Digest (G.R. No. 74070-71)
Facts:
- Parties and Property
- Petitioner: Sunshine Finance and Investment Corporation, as mortgagee and purchaser at foreclosure sale.
- Private respondents: Rodolfo Rubidizo and Alfredo De Guzman, claiming to have bought 112 sqm of the subject land on May 18, 1979.
- Original owner: Benito Vega, holding OCT No. 114; sold entire 222 sqm to spouses Romeo Nolasco and Erlinda de Belen (TCT No. 22198, March 26, 1980).
- Mortgage and foreclosure: Nolasco spouses mortgaged land to Sunshine (Feb. 13, 1981) for P52,466.34; loan unpaid, property foreclosed, Sunshine highest bidder; TCT No. 37772 issued in Sunshine’s name (May 26, 1982).
- Procedural History
- Writ of Possession (LRC Case No. R-3205): Sunshine successfully petitioned RTC Rizal; writ issued June 20, 1983.
- Third-party claim and separate recovery suit (Civil Case No. 50179): Respondents claimed 112 sqm purchased in 1979; two cases consolidated; respondents testified to immediate occupation and improvements.
- RTC Omnibus Order (Sept. 21, 1984): Dismissed Civil Case No. 50179; denied third-party claim in R-3205; enforced writ of possession; ordered respondents to remove improvements.
- Intermediate Appellate Court Decision (Mar. 18, 1986): Reversed RTC; applied exception to Torrens reliance rule—actual possession imposes duty to inquire; declared respondents owners of 112 sqm; ordered annotation on TCT No. 37772.
- Supreme Court Review: Petition for certiorari filed by Sunshine challenging IAC ruling.
Issues:
- Whether Sunshine, as mortgagee and purchaser at foreclosure sale, qualified as an innocent purchaser for value entitled to rely solely on the Torrens certificate and not inquire further.
- Whether actual possession of part of the land by third parties imposed on Sunshine a duty to inspect the property and investigate adverse claims.
- Whether respondents’ unregistered but actual purchase and occupation conferred rights enforceable against Sunshine’s registered title.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)