Case Summary (G.R. No. 205271)
Background of the Case
On November 20, 1996, Belle Corporation filed a Complaint for quieting of title against Bautista and the Register of Deeds of Tagaytay City, concerning four parcels of land in Barangay Sungay, Tagaytay City, with allegations of illegal construction on the disputed property. Bautista claimed title to the land under Transfer Certificate of Title (TCT) No. P-671, while Belle Corporation asserted ownership under TCT Nos. P-1863 to P-1866.
Substantive Legal Issues
The Court of Appeals annulled the Regional Trial Court's (RTC) earlier decision in favor of Bautista, ultimately ruling that Belle Corporation was the legitimate owner of the disputed property, issuing several orders regarding the cancellation and correction of titles.
Findings of the Lower Courts
The RTC ruled in favor of Bautista based on the priority of title registration. However, the Court of Appeals overturned this ruling, finding that Belle Corporation's title was indeed valid, and thus the earlier registration of Bautista’s title was annulled.
Appeals and Arguments
Belle Corporation contended that the Court of Appeals erred in its findings regarding the title verification survey, along with claims regarding the legality of its ownership. Land Bank asserted it was an innocent mortgagee for value. Both parties raised issues related to the sufficiency of evidence regarding the origins of their respective titles.
Decision of the Supreme Court
The Supreme Court denied Land Bank's petition for review. It affirmed the Court of Appeals' decision, emphasizing that Land Bank demonstrated bad faith by failing to conduct adequate due diligence concerning the title of the property it accepted as collateral.
Implications on Ownership and Mortgagee Status
The Supreme Court underscored that banks must exercise a higher degree of diligence compared to ordinary purchasers when dealing with property titles. This includes conducting thorough property inspections and inquiries to ensure clear ownership, especially when there are visible indications of potential claims on the property, as was the case with the existent access road leading to the Tagaytay Highlands.
Co
...continue readingCase Syllabus (G.R. No. 205271)
Case Background
- This case revolves around a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
- The petition seeks to reverse the November 23, 2011 Decision and January 17, 2013 Resolution of the Court of Appeals (CA) in CA-G.R. CV No. 84075.
- The CA annulled and set aside the April 12, 2004 Decision of the Regional Trial Court (RTC), Branch 18, Tagaytay City, in Civil Case No. TG-1672.
Parties Involved
- Petitioner: Land Bank of the Philippines
- Respondent: Belle Corporation, a publicly-listed company engaged in leisure and recreational development in Tagaytay City, Cavite.
- Third Parties: Florosa A. Bautista, the Register of Deeds of Tagaytay City, and Liezel's Garments, Inc.
Nature of the Dispute
- Belle Corporation filed a Complaint for quieting of title and damages against Bautista and the Register of Deeds on November 20, 1996.
- Respondent claims ownership of four parcels of land, totaling 317,918 square meters, covered by Transfer Certificates of Title (TCT) Nos. P-1863 to P-1866.
- Bautista contended that Belle Corporation illegally constructed a road on her property, which she claimed was registered under TCT No. P-671.
Timeline of Events
- October 31, 1996: Bautista's counsel sent a demand letter to Belle Corporation.
- November 1, 1996: Bautista posted a signboard asserting her ownership of the property.
- Dec