G.R. No. 157002 - Abad vs. Spouses Guimba

The Supreme Court only addresses questions of law in petitions for review under Rule 45 of the Rules of Court.
Factual questions must be elevated to the Court of Appeals, and the Supreme Court will not review them.
The petitioner, Jose T. Abad, failed to observe this principle, leading to the Court's refusal to consider whether he was a mortgagee in good faith and for value.
The trial court's factual findings are conclusive and binding in the current proceedings.

Respondent-Spouses Ceasar and Vivian Guimba are the registered owners of a parcel of land under Transfer Certificate of Title No. PT-80617.
Vivian Guimba entrusted her Owner's Duplicate Certificate of Title to Gemma de la Cruz as collateral for a loan but later sought its return after deciding against the loan.
The Guimbas learned of a mortgage on their property only when they received a telegram from petitioner Abad in November 1997.
After seeking legal advice, the Guimbas filed a complaint for annulment and cancellation of the mortgage against Abad and de la Cruz.

The trial court found Abad's testimonies to be conflicting and determined he had only dealt with de la Cruz, not the Guimbas.
Abad was deemed not to have acted in good faith as he failed to verify the identity and authority of the person he was dealing with.
The court ruled that the Deed of Mortgage was a forgery and ordered its cancellation, along with the return of the title to the Guimbas.
The court dismissed Abad's defense of laches, stating that Vivian Guimba had taken necessary steps to recover her title.

Abad raised three main issues regarding the applicability of PD 1529, the protection of innocent holders for value, and the doctrine of laches.
He questioned whether the provisions of PD 1529 would be ignored despite his status as an innocent third party.
He also argued that the Guimbas' delay in filing an adverse claim constituted laches.

The Court found that the petition lacked merit, emphasizing that the determination of good faith is a factual question already resolved by the RTC.
The Court reiterated that only questions of law are appropriate for Rule 45 petitions, and factual findings by the RTC are conclusive.
The Court ruled that Abad could not claim protection under PD 1529 as he was not an innocent mortgagee for value.

The purpose of land registration under PD 1529 is to facilitate real estate transactions by allowing reliance on the Torrens certificate of title.
However, this protection does not extend to those who are aware of defects in the title or who fail to make necessary inquiries.
The Court emphasized that Abad's failure to verify the identity of the person he was dealing with negated any claim of good faith.