Case Summary (G.R. No. L-14698)
Initial Transaction and Title Issuance
Originally, the two lots in question were owned by spouses Aventura and Galan, who were issued Original Certificate of Title No. C-153 following a cadastral ruling. The title was later cancelled as a result of a sale, directed by Atty. Elias Recto and facilitated by Adriano Coronado, whereby Collado and Provido purchased the properties for P4,000. Collado examined the title and believed it was free of encumbrances and liens. However, upon purchasing the land, Collado discovered claims to ownership by others only three months after the sale.
Judicial Proceedings
Following these discoveries, Collado and Provido filed a case in the Court of First Instance of Iloilo, seeking ownership and possession of the properties and demanding damages. The lower court initially ruled in favor of the petitioners, ordering the respondents to vacate the lots.
Court of Appeals Reversal
The Court of Appeals reversed this ruling, declaring the decree of registration from the cadastral case and the certificates of title null and void. They asserted that the petitioners acted in bad faith, citing evidence that suggested Collado was aware of existing claims to the property prior to purchasing it, undermining his assertion of good faith.
Examination of Good Faith
The Court of Appeals cited several findings to support its conclusion that the petitioners were aware of potential ownership claims by the respondents before completing their purchase. They noted that Collado, accompanied by police, visited the property and interacted with individuals cultivating it, later confirming that these individuals were claiming ownership.
Cadastral Proceedings and Nullification of Titles
The appellate court addressed the issue of the nullification of the decree of registration and the subsequent titles issued to the petitioners. The respondents filed their petitions for review within the legally mandated one-year period, which allowed for such actions without constituting a collateral attack. The appellate court emphasized that th
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Case Citation
- 117 Phil. 514
- G.R. No. L-14698
- March 30, 1963
Parties Involved
- Petitioners: Jose E. Collado and Aurora Provido
- Respondents: The Hon. Court of Appeals, Nicomedes Copiat, et al.
Judicial Authority
- Justice Bautista Angelo presided over the decision.
Case Background
- This case is a petition for review concerning a decision by the Court of Appeals that reversed a previous ruling by the Court of First Instance.
- The original court order mandated Nicomedes Copiat and others to vacate two lots and return possession to the registered owners, Jose E. Collado and Aurora Provido.
Property Details
- The two lots in question were initially registered under the names of spouses Pedro Aventura and Anacleta Galan, who were issued Original Certificate of Title No. C-153 following a decision in Cadastral Case No. 88 on January 26, 1951.
- The lots were sold to Jose E. Collado and Aurora Provido for P4,000.00, facilitated by Atty. Elias Recto and Adriano Coronado.
Purchase Process
- Prior to the purchase, Collado examined the title, which appeared to be free from liens and encumbrances.
- Collado inspected the land and encountered Nicomedes Copiat, who was identified as a tenant by Anacleta Galan, reinforcing Collado's belief about the land's ownership.
- Following