Facts:

The case arises from a petition for review on certiorari filed by Felix B. Tiu (petitioner) against Spouses Jacinto Jangas and Petronila Merto-Jangas, along with other intervenors including Spouses Maria and Melencio Ortiz, Spouses Merla and Pacito Kitane, Spouses Candelaria and Rodrigo Rusiana, Juana T. Jalandoni, and Spouses Adelaida P. Ragay and Teofisto Ragay, Sr. The dispute concerns a parcel of land designated as Lot No. 480-A in Salag, Siaton, Negros Oriental, originally owned by Gregorio Pajulas. Gregorio, during his lifetime, divided his property, granting a portion to his granddaughter and later, upon his death in 1956, the rest of the land was inherited by his three daughters—Adelaida, Bruna, and Isabel. In 1962, the daughters partitioned Lot No. 480-A among themselves.

The title to Lot No. 480-A was compromised through a series of transactions: Bruna sold her one-third share to Spouses Gaudencio and Lucia Amigo-Delayco, who later obtained a free patent over the enti

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Facts:

Origin of the Case and Parties Involved

• A complaint for reconveyance of property was filed on August 6, 1992 by Spouses Jacinto and Petronila Merto-Jangas (Spouses Jangas) against Felix Tiu (petitioner) and Rural Bank of Amlan, Inc. (RBAI).
• The subject matter is a parcel of land designated as Lot No. 480-A, originally owned by Gregorio Pajulas, with an area of 25,340 square meters, located in Salag, Siaton, Negros Oriental.

History of the Property and Its Partitioning

• During Gregorio’s lifetime, he owned a contiguous parcel of land (Lot No. 480) and later gave a portion (Lot No. 480-B) to his granddaughter.
• Upon his death in 1956, Gregorio was survived by his three daughters—Adelaida, Bruna, and Isabel—who adjudicated the remaining land (Lot No. 480-A) in their names under Tax Declaration No. 17560.
• In 1962, the Pajulas sisters agreed to partition the remaining land equally among themselves.
• After the death of Isabel, her share passed to her heirs, namely her husband and children (the Gadiane sisters).

Chain of Transactions and Sales

• Norma sold a portion of her share (1,462 sq m) to Spouses Jangas on August 5, 1974, declared under TD No. 21-827.
• Iluminada and Norma sold another portion (912 sq m) to Spouses Jangas on December 31, 1981, declared under TD No. 21-1064.
• Iluminada also made subsequent sales:
• 288 sq m to Candelaria Rusiana.
• 3,243 sq m to Merla Macalipay-Kitane.
• 288 sq m to Juana Jalandoni.
• Bruna sold her one-third share of Lot No. 480-A to Spouses Gaudencio and Lucia Amigo-Delayco (Spouses Delayco) in 1962.

Title Registration and Subsequent Conveyances

• On January 8, 1980, the heirs of Gaudencio, represented by Bridiana Delayco, applied for and obtained a free patent covering the entire Lot No. 480-A, resulting in OCT No. FV-29932.
• Bridiana subsequently transferred the title solely into her name, receiving TCT No. FT-4925 on September 26, 1985, which was further validated by a tax declaration (TD No. 21-1031).
• In March 1990, Bridiana sold the subject property to the petitioner.
• On August 24, 1990, TCT No. FT-5683 was issued to Spouses Felix and Evelyn Tiu, and the property was duly declared under their names; in 1991, the property was mortgaged with RBAI.

Consolidation of Litigation and Interventions

• The Spouses Jangas pursued reconveyance and damages based on their claim of ownership, prompting a trial in the RTC of Dumaguete City, Branch 35 (Civil Case No. 10278).
• Intervening parties—Spouses Ortiz, Kitane, Rusiana, Juana, and later Spouses Ragay—alleged their acquisition of different portions of Lot No. 480-A from the Gadiane sisters.
• The trial court ruled in favor of the intervenors by partitioning the property:
• Declaring Spouses Jangas as part owners of a specific 2,374-square meter portion.
• Recognizing the petitioner’s interest only in the one-third portion (middle share) that was mortgaged to RBAI.
• Allocating the remaining portions to the heirs of Adelaida and Isabel, respectively.
• Ordering the partial cancellation of TCT No. FT-5683 to reflect the rights of all legitimate owners.

Appellate and Supreme Court Proceedings

• On August 31, 2010, the CA affirmed the RTC decision, holding that Bruna could only transfer her one-third share, in line with the principle nemo dat quod non habet.
• The petitioner’s motion for reconsideration was denied by the CA on December 6, 2011.
• Consequently, the petitioner elevated the case to the Supreme Court through a petition for review on certiorari.

Issue:

Primary Issue

• Whether the petitioner is entitled to reconveyance of the subject property.

Questions of Title and Good Faith

• Whether the petitioner, having acquired the property from Bridiana, obtained it in good faith, for value, and without notice of existing claims.
• Whether registration under the Torrens system (TCT No. FT-5683) guarantees absolute ownership despite conflicting prior interests.

Extent of Ownership Transferred

• Whether Bruna’s sale via Spouses Delayco was limited to her one-third share of Lot No. 480-A or improperly purveyed the entire property.
• How the prior partition of the land among the heirs affects the petitioner’s title claim.

Implications of Negligence and Bad Faith

• Whether the petitioner’s knowledge of the existence of other occupants and structures on the property negates his claim as an innocent purchaser.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)