Case Summary (G.R. No. 188395)
Background of the Property Dispute
The property dispute arose from a parcel of land measuring 6,407 square meters, initially registered under TCT No. T-9830 in the name of Felix M. Bucton. The conflict began when Felix received a phone call from Gonzalo Go, informing him that he had purchased the land via Benjamin Belisario, whom Felix had allegedly authorized to sell the property through a Special Power of Attorney (SPA). This SPA was later contested by the Heirs of Felix, who claimed the signatures on the document were forged.
Legal Proceedings Initiated by the Heirs
In February 1996, the Heirs of Felix initiated a legal action before the Regional Trial Court (RTC) of Misamis Oriental, seeking annulment of the SPA and associated transactions, recovery of ownership, and possession of the property. They contended that since the SPA was fraudulent, ownership had not been effectively transferred to the Spouses Go.
Response from the Spouses Go
The Spouses Go, contesting the claims of the Heirs, asserted they were buyers in good faith with no knowledge of the alleged forgery. They argued that the Torrens system allows buyers to rely on the correctness of the certificate of title, disseminating the presumption of good faith in their purchase.
Judgment of the RTC
On June 25, 2005, the RTC dismissed the Heirs' complaint, ruling it was barred by laches and prescription. The court determined that the Heirs did not pursue their claims diligently from the time of the alleged fraudulent transaction in 1981 until 1996, thus concluding the case in favor of the Spouses Go.
Affirmation by the Court of Appeals
The Court of Appeals affirmed the RTC's decision in a ruling dated May 27, 2009, holding that the Heirs did not sufficiently prove the SPA was forged, thus maintaining the validity of the Spouses Go's title. The appellate court concluded that the Spouses Go were innocent purchasers for value.
Examination of Forgery Claims
The Supreme Court found merit in the Heirs' petition, emphasizing that claims of forgery must be supported by clear evidence. The Heirs presented expert testimony which identified significant discrepancies in the signatures attributed to Felix. The Court highlighted that competent evidence demonstrating the forgery sufficed to invalidate the presumption of regularity afforded to the notarized document.
Determination of Innocent Purchaser Status
The Supreme Court analyzed whether the Spouses Go acted as innocent purchasers in good faith. It stated that good faith requires buyers to verify an agent's authority before transacting. In this case, the Spouses Go dealt with an agent, thereby bearing the responsibility to ascertain the agent's legitimac
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Case Overview
- This case involves a Petition for Review on Certiorari filed by the Heirs of Felix M. Bucton challenging the Decision of the Court of Appeals which affirmed the ruling of the Regional Trial Court (RTC) favoring the Spouses Gonzalo and Trinidad Go regarding ownership of a disputed property.
- The appellate court's decision, dated May 27, 2009, upheld the title of the Spouses Go, registered under Transfer Certificate of Title (TCT) No. T-34210, and dismissed the complaint filed by the Heirs of Felix for lack of merit.
Factual Background
- The property in question is a 6,407 square meter parcel of land located in Lapasan, Cagayan de Oro City, originally owned by Felix M. Bucton and covered by TCT No. T-9830.
- In March 1981, Felix was informed by Gonzalo Go that he had purchased the property through an alleged attorney-in-fact, Benjamin Belisario.
- The Heirs of Felix claimed that the original certificate of title was lost and later fell into the hands of individuals who conspired to deprive Felix of his ownership.
- A Special Power of Attorney purportedly signed by the Spouses Bucton on February 27, 1981, was used to facilitate a Deed of Absolute Sale in favor of the Spouses Go, leading to the cancellation of Felix's title and the issuance of a new title in the names of the Spouses Go.
Legal Proceedings
- Following Felix's death, his heirs filed a complaint on February 19, 1996, alleging the signatures