Case Summary (G.R. No. L-48322)
Material Facts Regarding Ownership, Transfers and Titles
- The spouses Juan and Fortunata died intestate; their heirs were Candida, Victoriana, and Agapita (each one-third pro indiviso). Candida administered the properties until her death in 1955.
- In 1943 Candida, with Eulogio Bandin and Agapita, caused a sale of a portion of the Talon property to Rufino Miranda and Natividad Guinto, producing Parcels 1–3; Parcel 1 (24,363 sq.m.) passed through subsequent purchasers and was registered (OCT No. 1756 → later TCT No. 165335). Parcels 2 and 3 were sold and registered in the names of Jose and Sotero Ramirez (OCT Nos. 2027 and 2029).
- Remaining Talon acreage was extrajudicially partitioned among Candida’s heirs in 1955 and subdivided in 1959 (Subdivision Plan PSU-173299) into seven lots later registered in the names of various heirs and transferees (including titles later issued and some later transferred to third parties, e.g., TCT Nos. 227470/227471, 10002, 6102, 3706, 116450, 3707, 6103).
- The Laong parcel was sold in 1943 by Candida and children to Hermogenes Lucena (husband of Juanita Martin). Juanita later sold to Gregorio and Mary Venturanza in 1959. The Venturanzas sold a 15,000 sq.m. portion to Felipe and Antonia David in 1965. Juanita obtained registration (OCT No. 8916) in 1971; the portion sold to Felipe and Antonia David is covered by TCT No. 372092.
Trial Court Findings and Relief Awarded
The trial court concluded the Talon and Laong parcels formed part of the decedents’ estate and passed to Candida, Victoriana and Agapita (each 1/3). Because there was no settlement of the estate, the heirs remained pro indiviso co-owners; after Candida’s and Victoriana’s deaths their shares passed to their heirs. The trial court awarded plaintiffs (Agapita and heirs of Victoriana) two-thirds pro indiviso and ordered reconveyance by the heirs of Candida of plaintiffs’ respective shares, except for parcels already sold to third parties who were found to be purchasers in good faith for value. For parcels that could not be reconveyed, the court required the selling heirs to pay plaintiffs two-thirds of the present value of those parcels. The trial court identified specific purchasers as good-faith buyers for certain parcels (e.g., Velasquez Realty for Parcel 1; Jose and Ambrocia Ramirez for Parcels 2 and 3; Consolacion de la Cruz; Nemesio Martin; Magno de la Cruz re: portions of lots; Felipe and Antonia David re: 15,000 sq.m. of Laong).
Court of Appeals Modifications
The Court of Appeals reversed the trial court’s findings that the third-party purchasers were bona fide purchasers for value in certain instances. Concretely, the CA: (a) nullified the 1943 sale of the Laong property by Candida and her children to Hermogenes Lucena and all subsequent transfers affecting plaintiffs’ two-thirds share; (b) nullified the 1943 sale of portions of Talon to the Mirandas and subsequent transfers insofar as they affected the four-fifteenths share of certain Bandin and Briones heirs; and (c) invalidated the 1955 extrajudicial partition and subsequent subdivision and transfers insofar as they affected plaintiffs’ two-thirds pro indiviso share. The CA thus afforded plaintiffs broader remedies against subsequent transferees than the trial court had.
Issues Presented on Certiorari and Parties’ Principal Contentions
Petitioners advanced separate claims: (1) some argued plaintiffs’ claims were barred by prescription or laches; (2) certain petitioners invoked res judicata and the incontrovertibility of Torrens registration (arguing that decrees of registration and certificates conferred conclusive title); (3) purchasers of unregistered land contended they were bona fide purchasers for value and should be protected; (4) purchasers of registered titles (notably Magno de la Cruz) contended CA erred in invalidating registered transfers affecting their Torrens titles.
Supreme Court Analysis — Prescription, Laches, and Res Judicata
The Court affirmed the trial court and CA in rejecting prescription and laches defenses. It emphasized that prescription generally does not run against a co-heir or co-owner while the co-ownership is recognized expressly or impliedly (Article 494 New Civil Code / Article 400 old). The evidence did not show Candida repudiate plaintiffs’ co-ownership during her lifetime; plaintiffs made demand in April 1963 and filed suit in June 1963, within roughly eight years of Candida’s death. On res judicata, the Court held that the decree of registration in favor of Juanita (in a prior land registration proceeding) could not bar plaintiffs because they were not parties to that registration case; moreover, the purpose of the Land Registration Act is to confirm and register an existing title, not to create ownership where none exists.
Supreme Court Analysis — Purchasers of Unregistered Land and Good-Faith Protection
The Court reiterated the principle that the doctrine protecting a bona fide purchaser for value applies principally in the context of registered land where the purchaser relies on the registered owner’s title. Purchasers of unregistered land purchase at their peril: a claim of good faith does not protect a purchaser from losing property where the seller lacked title. Applying that principle, the Court held: (a) the spouses Felipe and Antonia David, who bought a 15,000 sq.m. portion of Laong in 1965 from Venturanzas when the land was unregistered, could not claim protection as bona fide purchasers and were not entitled to retain the plaintiffs’ two-thirds pro indiviso share; (b) Jose Ramirez and Sotero Ramirez, who bought Parcels 2 and 3 (unregistered) from the Mirandas in 1948–1949, were not bona fide purchasers for value; the CA properly found that they had failed to make diligent inquiry and relied merely on a tax declaration shown by the seller.
Supreme Court Analysis — Purchaser of Registered Land (Magno de la Cruz)
The Court distinguished the case of Magno de la Cruz: he acquired portions of the Talon property that were already registered under Torrens titles issued to his vendors Victoria Martin and Maximina Martin. Because Magno purchased registered land and there was no showing he had actual notice of any defect in the vendors’ title or that he acted in bad faith, he was protected by the Torrens system. Consequently, the CA erred in invalidating the sale to Magno and cancelling Transfer Certificate
Case Syllabus (G.R. No. L-48322)
Procedural History and Consolidation
- The petitions before the Court were consolidated by resolution dated February 20, 1980; they arise from an original complaint filed June 14, 1963 in the Court of First Instance of Rizal, Branch VII, Pasay City, for recovery and partition of property.
- The complaint was amended twice to reflect additional facts (transfers, partitions, subdivisions, registration of portions) and to implead indispensable parties.
- On April 12, 1975, the trial court rendered judgment for plaintiffs, declaring certain properties as part of the estate of the spouses Juan Ramos and Fortunata Calibo and ordering reconveyance of defendants’ shares to plaintiffs except for portions sold to purchasers in good faith for value.
- Both plaintiffs and defendants appealed to the Court of Appeals; plaintiffs’ appeal docketed CA-G.R. No. 58647-R; defendants’ appeal docketed CA-G.R. No. 60511-R; both appeals consolidated.
- The Court of Appeals rendered decision on May 19, 1978, modifying the trial court by nullifying certain transfers previously held by trial court to be to purchasers in good faith.
- Various parties adversely affected appealed to the Supreme Court by separate petitions for review by certiorari; petitions were identified by G.R. Nos. L-48322, L-49712, L-49716, L-49687 and were consolidated for decision.
Principal Facts: Original Ownership and Heirs
- During their lifetimes, spouses Juan Ramos (d. March 5, 1919) and Fortunata Calibo (died before 1919) owned two parcels in Las Piñas, Rizal:
- Talon property: Barrio Talon, area 39,887 sq. m., Tax Declaration No. 9614.
- Laong property: Barrio Laong, declared area 15,993 sq. m. under Tax Declaration No. 4005, surveyed area 22,288 sq. m.
- Spouses died intestate, leaving as heirs two legitimate children, Candida and Victoriana Ramos, and a granddaughter Agapita Ramos (daughter of deceased son Anastacio).
- Candida Ramos administered the properties until her death on February 16, 1955; Victoriana Ramos died December 12, 1931; both died intestate.
- Heirs of Candida Ramos included: Victoria Martin-Omanbac, Antonio Martin, Juanita Martin Vda. de Lucena, Maximina Martin Vda. de Cosme, Raymundo Martin, Aquilina de la Cruz, Leonora de la Cruz.
- Heirs of Victoriana Ramos (by two marriages) included: Eulogio Bandin, Gregorio Bandin, Raymunda Bandin, Valentin Briones, Sofio Briones.
Transactions and Changes in Title — Talon Property (parceling and dispositions)
- In 1943 Candida Ramos induced her niece Agapita Ramos and nephew Eulogio Bandin to sell a portion of the Talon property to spouses Rufino O. Miranda and Natividad Guinto.
- That portion was divided into three parcels:
- Parcel 1: area 24,363 sq. m., Tax Declaration No. 2996 (1948). Rufino & Natividad Miranda subsequently sold to Narciso Velasquez and Albino Miranda; these sold to Velasquez Realty Company, Inc.; registered under OCT No. 1756 (later cancelled and replaced by TCT No. 165335).
- Parcel 2: area 752 sq. m., Tax Declaration No. 3358 (1949). Sold by Rufino & Natividad Miranda to Jose Ramirez; registered under OCT No. 2027 in his name.
- Parcel 3: area 516 sq. m., Tax Declaration No. 3359 (1949). Sold by Rufino & Natividad Miranda to Sotero Ramirez (survived by Ambrocia Vda. de Martin); registered under OCT No. 2029.
- Remaining portion of Talon property underwent an extrajudicial partition on September 17, 1955 among heirs of Candida Ramos (Juanita, Victoria, Maximina, Antonio, Raymundo).
- In 1959 subdivision plan PSU-173299 subdivided remaining Talon property into seven lots with adjudications and later registrations:
- Lot 1 (774 sq. m.): adjudicated to heirs of Raymundo Martin; later sold to Consolacion de la Cruz and registered under OCT No. 4731 (later cancelled and replaced by TCT Nos. 227470 and 227471).
- Lot 2 (774 sq. m.): adjudicated to Juanita Martin; later titled in her name under OCT No. 10002, issued Dec. 18, 1973.
- Lot 3 (346 sq. m.): adjudicated to Leonora de la Cruz; declared under Tax Declaration No. 5526 (1960); registered under OCT No. 6102, issued Jan. 29, 1967.
- Lot 4 (774 sq. m.): adjudicated to Antonio Martin; subsequently sold by his heirs to Nemesio Martin.
- Lot 5 (773 sq. m.): adjudicated to Victoria Martin; declared under Tax Declaration No. 5590; registered with OCT No. 3706, issued Aug. 22, 1963; Victoria sold portion of 300 sq. m. to Magno de la Cruz on Sept. 25, 1963 (TCT No. 116450).
- Lot 6 (773 sq. m.): adjudicated to Maximina Martin; Tax Declaration No. 5591 (1960); registered under OCT No. 3707, issued Aug. 22, 1963; Maximina sold portion of 300 sq. m. to Magno de la Cruz (TCT No. 116450).
- Lot 7 (428 sq. m.): adjudicated to Aquilina de la Cruz; Tax Declaration No. 5592 (1960); registered under OCT No. 6103 (1967).
Transactions and Changes in Title — Laong Property (sales, registration, and subsequent conveyances)
- Laong property was sold by Candida Ramos and her children on December 19, 1943 to Hermogenes Lucena (husband of Juanita Martin).
- On September 23, 1959, Juanita (then widowed) sold the Laong property to spouses Gregorio and Mary Venturanza for P43,236.00 (P10,000 down; balance upon vendor obtaining Torrens title).
- On January 21, 1965 the Venturanzas, in a deed of sale also signed by Juanita Martin, conveyed a portion of 15,000 sq. m. to spouses Felipe and Antonia David in liquidation of the latter's investment in a joint real estate venture with the Venturanzas begun April 1959.
- Juanita Martin Vda. de Lucena obtained Torrens registration: OCT No. 8916 issued July 1, 1971.
- The portion sold to Felipe and Antonia David is presently covered by TCT No. 372092.
Trial Court Findings and Relief (April 12, 1975 decision)
- Trial court held Talon and Laong properties were part of the estate of spouses Juan Ramos and Fortunata Calibo and devolved upon heirs Candida, Victoriana and Agapita Ramos, each entitled to one-third (1/3) pro indiviso.
- No judicial or extrajudicial settlement of the estate had been made; heirs remained pro indiviso co-owners; upon deaths of Victoriana and Candida their shares passed to their heirs.
- Plaintiffs (Agapita Ramos and heirs of Victoriana) were declared entitled to two-thirds (2/3) pro indiviso share of Talon and Laong properties.
- Defendants heirs of Candida Ramos were ordered to reconvey to plaintiffs their shares, except where reconveyance was impossible because portions had been sold to purchasers in good faith for value.
- Trial court identified purchasers in good faith with respect to specified parcels and titles:
- Rufino Miranda, Narciso Velasquez, Albino Miranda, Velasquez Realty Co. — Parcel 1 (24,636 sq. m.) of Talon (sale 1943).
- Jose Ramirez and Ambrocia Vda. de Ramirez — Parcels 2 and 3 (752 sq. m. and 516 sq. m.) of Talon.
- Consolacion de la Cr