Case Summary (G.R. No. 214741)
Petitioner
Tiburcio Samonte, successor-in-interest to purchasers of subdivided portions of Lot 216, holding TCT Nos. RT-553 and RT-1658.
Respondents
Surviving heirs of Apolonia Abao and Irenea Tolero: Eugenia Dango Gadiano, Teofilo Gadiano, Petronilo Dango, Feliciana Dango, Nonilo Marave, and Geronimo Dango.
Key Dates
• 1927 – Issuance of OCT No. RO-238 to Abao and Tolero
• Aug. 8, 1957 – Reconstitution and fraudulent cancellation of OCT No. RO-238(555); issuance of TCT No. RT-476 to Nicolas and Beatriz Jadol
• Feb. 13, 1959 – Subdivision into Lots 216-A/-B and further into 216-B-1/-B-2; issuance of TCT Nos. RT-553, RT-554, RT-555, RT-556
• 1975 – Respondents filed Civil Case No. 1816 for reconveyance and quieting of title
• Nov. 29, 1991 – Court of Appeals decision affirming trial court
• July 12, 2001 – Supreme Court resolution of G.R. No. 104223
Applicable Law
• 1987 Philippine Constitution (post-1990 decision)
• Civil Code Art. 1456 on implied trusts for fraudulently acquired property
• Section 51, Act No. 496 (as amended by PD No. 1529 Sec. 52) – Torrens title constructive notice
• Relevant jurisprudence: Adille v. Court of Appeals (157 SCRA 455 [1988]); Carantes v. Court of Appeals (76 SCRA 514)
Factual Background
Respondents, as heirs, claimed one-half of Lot 216 registered to Tolero and the other half to Abao. In 1957, Ignacio Atupan executed an extrajudicial settlement affidavit falsely representing himself as Abao’s sole heir, causing cancellation of OCT No. RO-238(555) and issuance of TCT No. RT-476 to the Jadols. Subsequent subdivisions and sales by Jadols and Tagorda transferred portions to Samonte, who held them in his name and paid property taxes.
Procedural History
Two related actions were filed in the Regional Trial Court:
• No. 1672 – Quieting of title for Lot 216-B-2-G
• No. 1816 – Quieting of title and reconveyance for entire Lot 216, annulling all intervening titles
Both were consolidated for trial, and the court granted respondents’ petitions, reinstating OCT No. RO-238(555), canceling all subsequent titles, and ordering defendants’ ejectment, damages, attorney’s fees, and costs. Appeals to the Court of Appeals were dismissed, and this petition followed.
Issues Presented
- Whether the action for reconveyance was barred by the four-year prescription from discovery of fraud upon registration.
- Whether Samonte qualified as a purchaser in good faith.
Court of Appeals Ruling
The CA held that:
• The Jadols effected TCT No. RT-476 through fraud, with actual knowledge, thus in bad faith.
• Respondents’ action was grounded on an implied trust under Civil Code Art. 1456, subject to a ten-year prescription counted from discovery of fraud, not merely from registration. Discovery occurred only during trial.
• Samonte purchased with constructive notice of respondents’ claim, and also had actual knowledge of the Jadols’ defect in title; hence he was in bad faith and not protected as a bona fide purchaser.
Supreme Court Ruling
The Supreme Court affirmed the CA decision in toto, denying the petition for lack of merit.
Case Syllabus (G.R. No. 214741)
Relevant Facts and Procedural History
- Lot 216 in Nasipit, Agusan del Norte (12,753 m²) was originally registered under OCT No. RO-238(555) in the names of Apolonia Abao and her daughter Irenea Tolero, pro indiviso.
- After the deaths of Abao (during WWII) and Tolero (1945), their surviving heirs—respondents here—claimed ownership of the entire lot.
- In 1957, Ignacio Atupan executed a fraudulent affidavit of extrajudicial settlement to cancel OCT No. RO-238(555), leading to TCT No. RT-476 in favor of Irenea Tolero and Nicolas Jadol.
- February 13, 1959: Lot 216 was subdivided into Lot 216-A (now under TCT RT-553 in Samonte’s name) and Lot 216-B (TCT RT-554 in the names of Tolero and Jadol). Lot 216-B itself was further split into Lot 216-B-1 (Tagorda) and Lot 216-B-2 (Tolero & Jadol).
- Civil Case No. 1816 (subject of this petition) was filed by Abao’s and Tolero’s heirs for quieting of title, annulment of fraudulent TCTs, reinstatement of OCT No. RO-238(555), and recovery of possession.
- Petitioner Samonte invoked his purchase in good faith, adverse possession, tax declarations, and long possession as a basis for his claim.
Legal Issues Presented
- Whether the cancellation of OCT No. RO-238(555) and issuance of subsequent titles (beginning with TCT RT-476) were invalid due to fraud.
- Whether respondents’ action for reconveyance is barred by prescription, given the Torrens registration doctrine.
- Whether petitioner Samonte is a buyer in good faith protected by the