ADORACION ROSALES RUFLOE v. LEONARDA BURGOS, GR No.

143573, 2009-01-30
Facts:
Petitioner Adoracion Rufloe is the wife of Angel Rufloe, now deceased, while co-petitioners Alfredo and Rodrigo are
their children. During the marriage of Adoracion and Angel, they acquired a 371-square meter parcel of land covered by
Transfer Certificate of Title (TCT) No. 406851 which is the subject of the present controversy.
Sometime in 1978, respondent Elvira Delos Reyes forged the signatures of Adoracion and Angel in a Deed of Sale dated
September 8, 1978 to make it appear that the disputed property was sold to her by the spouses Rufloe. The basis of the
said deed of sale, Delos Reyes succeeded... in obtaining a title in her name, TCT No. S-74933.
December 4, 1984, during the pendency of Civil Case No. M-7690, Delos Reyes sold the subject property to respondent
siblings Anita, Angelina, Angelito and Amy (Burgos siblings). A new title, TCT No. 135860, was then issued in their names.
On December 12, 1985, the Burgos siblings, in turn, sold the same property to their aunt, Leonarda Burgos. However,
the sale in favor of Leonarda was not registered. Thus, no title was issued in her name.
The trial court ruled... that Delos Reyes did not acquire ownership over the subject property. Said decision had become
final and execut... the trial court rendered a decision declaring that Leonarda and the Burgos siblings were not innocent
purchasers for value and did not have a better right to the property in question than the true and legal owners, the
Rufloes. The trial court also held... that the subsequent conveyance of the disputed property to Leonarda by the Burgos
siblings was simulated to make it appear that Leonarda was a buyer in good faith
Issues:
Whether respondents were innocent purchasers in good faith and for... value despite the forged deed of sale of their
transferor Delos Reyes.
Ruling:
a person dealing with registered land has a right to rely on the Torrens certificate of title and to dispense with the need
of inquiring further except when the party has actual knowledge of facts and circumstances that would impel a
reasonably cautious man to... make such inquiry or when the purchaser has knowledge of a defect or the lack of title in
his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property
in litigation.
The presence of anything which excites or... arouses suspicion should then prompt the vendee to look beyond the
certificate and investigate the title of the vendor appearing on the face of said certificate. One who falls within the
exception can neither be denominated an innocent purchaser for value nor a purchaser in good... faith and, hence, does
not merit the protection of the law... at the time the Burgos siblings bought the subject property on December 4, 1984.
This circumstance should have alerted the Burgos siblings as to the validity of Delos Reyes' title and her authority and
legal right to sell the property.
. It was Amado Burgos who bought the property for his children, the Burgos siblings. Amado was not personally
acquainted with Delos Reyes... prior to the sale because he bought the property through a real estate broker, a certain
Jose Anias, and not from Delos Reyes herself.
There was no showing that Amado or any of the Burgos siblings exerted any effort to personally verify with the Register
of Deeds if Delos Reyes'... certificate of title was clean and authentic.
In the same vein, Leonarda cannot be categorized as a purchaser in good faith. Since it was the Rufloes who continued
to have actual possession of the property, Leonarda should have investigated the nature of their possession.

64. HEIRS OF CABIGAS vs. LIMBACO

G.R. G.R. No. 175291
July 27, 2011

FACTS:

Ines Ouano sold to Salvador Cobarde 2 lots in 1948. Notwithstanding the sale between Ouano and Cobarde, and because the two lots
remained registered in her name, Ouano was able to sell these same lots to the National Airports Corporation on November 25,
1952 for its airport expansion project. The National Airports Corporation promptly had the titles of these properties registered in its
name. However, in1980, Cobarde sold these 2 lots to Lolita Cabigas and her late husband, Nicolas Cabigas.
When the airport expansion project fell through, the legal heirs of Ouano succeeded in reclaiming title to the two lots through an
action for reconveyance filed with the lower court.1 The heirs of Ouano then registered these lots in their names and then subdivided
them and sold them to New Ventures Realty Corporation, Eugenio Amores, Henry See, Freddie Go, Benedict Que, Petrosa, and
AWG. AWG, in turn, sold one of the parcels of land to UCB. All the buyers registered the titles over their respective lots in their
names.

The heirs of Cabigas filed this action for annulment of the said titles but the RTC dismissed their action saying that the National
Airport Corporation was a buyer in good faith, and having registered the lot in its name, Cobarde’s rights to the properties had been
cut off. Hence, under the Torrens system, the petitioners are strangers to the lots and they had no legally recognized interest binding it
in rem that the courts could protect and enforce against the world.

CA dismissed the case as it did not have jurisdiction to entertain the appeal since it raised a pure question of law. As the appeal was
dismissed based on a technicality, CA did not have the jurisdiction to order that the case be remanded to the RTC.

ISSUES:

(1) The CA committed grave and serious error in dismissing the appeal and in holding that a summary judgment is appealable only
through a petition for review on certiorari under Rule 45 to the Supreme Court.

(2) The paramount and overriding considerations of substantial justice and equity justify the reversal and setting aside of the
questioned resolutions.

HELD:

The CA correctly dismissed the action. Section 2, Rule 41 of the Rules of Court provides the three modes of appeal: Ordinary appeal,
petition for review, and appeal by Certiorari. The first mode of appeal, the ordinary appeal under Rule 41 of the Rules of Court, is
brought to the CA from the RTC, in the exercise of its original jurisdiction, and resolves questions of fact or mixed questions of fact
and law. The second mode of appeal, the petition for review under Rule 42 of the Rules of Court, is brought to the CA from the RTC,
acting in the exercise of its appellate jurisdiction, and resolves questions of fact or mixed questions of fact and law. The third mode of
appeal, the appeal by certiorari under Rule 45 of the Rules of Court, is brought to the Supreme Court and resolves only questions of
law.

Where a litigant files an appeal that raises only questions of law with the CA, Section 2, Rule 50 of the Rules of Court
expressly mandates that the CA should dismiss the appeal outright as the appeal is not reviewable by that court.

The Cabigas spouses are not buyers in good faith. We are dealing with registered land, a fact known to the Cabigas spouses since they
received the duplicate owner’s certificate of title from Cobarde when they purchased the land. At the time of the sale to the Cabigas
spouses, however, the land was registered not in Cobarde’s name, but in Ouano’s name. By itself, this fact should have put the
Cabigas spouses on guard and prompted them to check with the Registry of Deeds as to the most recent certificates of title to discover
if there were any liens, encumbrances, or other attachments covering the lots in question.

As to whether the National Airports Corporation is a buyer in good faith, there was never any imputation that it was a buyer in bad
faith or that it registered the said lots in bad faith.

66. Hector Uy vs. Virginia Fule

G.R. No. 164961 (2014)
BUYER IN GOOD FAITH
Generally, a buyer is not required to inquire beyond the title if the requisites of good faith concur. However, absent one or two of the
requisites, then the law itself puts the buyer on notice and obliges the latter to exercise a higher degree of diligence by scrutinizing the
certificate of title and examining all factual circumstances in order to determine the seller’s title and capacity to transfer any interest in the
property.
FACTS: Conrado Garcia (CG) owned a vast tract of land. Upon his death, his heirs entered an extrajudicial settlement of his estate including
the land and thereafter caused its registration under their names. Meanwhile, DAR officials issued a joint certification that said land was an
“untitled” property owned by CG. As such, it was then included in the Operation Land Transfer program pursuant to PD No. 27. The offices
issued Emancipation Patents and Original Certificate of Titles to farmer-beneficiaries like Mariano Ronda (MR). MR sold his portion to
Chisan Uy then Chisan Uy’s heirs, sold the said land to Hector Uy. In 1997, the TCT of CG was cancelled and subsequently issued in the
names of the heirs of Garcia under a new TCT. In 1998, DAR Secretary issued the EPs to farmer-beneficiaries like MR. However, CG’s TCT
was already in the name of Hector Uy. Because of this, the heirs of CG filed a complaint assailing the certificates of titles issued to
purchasers Chisan and Hector Uy. RTC favored respondents. CA affirmed. SC affirmed CA.
SUBSTANTIVE ISSUE: WON Hector Uy, who got the land from the heirs of the farmer beneficiary Mariano Ronda, was an innocent purchaser
for value who had better rights than the heirs of Conrado Garcia over the disputed land. (NO. He did not exercise reasonable precaution by
inquiring beyond the title. Third requisite was absent. Hence, he cannot be awarded the disputed land.)
RATIO:
There is good faith when the following conditions concur:

1. the seller is the registered owner of the land;

2. the latter is in possession thereof; and
3. at the time of the sale, the buyer was not aware of any claim or interest of some other person in the property,
or of any defect or restriction in the title of the seller or in his capacity to convey title to the property.
Absent one or two of the foregoing conditions, then the law itself puts the buyer on notice and obliges the latter to exercise
a higher degree of diligence by scrutinizing the certificate of title and examining all factual circumstances in order to determine the seller’s
title and capacity to transfer any interest in the property. Under such circumstance, it was no longer sufficient for said buyer to merely
show that he had relied on the face of the title; he must now also show that he had exercised reasonable precaution by inquiring beyond
the title. Failure to exercise such degree of precaution makes him a buyer in bad faith.
In this case, the deed of sale executed between the heirs of Ronda and the petitioner were issued only on August 17, 1998 but the
deed of sale was executed on July 31, 1998. Evidently, the petitioner entered into the deed of sale without having been able to inspect the
TCTs since they were still inexistent. His only basis were the OCTs and such categorically stated that they were entered pursuant to an
emancipation patent pursuant to Operation Land Transfer. It provided that it shall not be transferred except by hereditary succession or to
the government. Hence, the third element was negated. At the time of the sale, the buyer was already aware of any restriction in the title
of the seller or in his capacity to convey title to the property. The absence of the third condition put the petitioner on notice and obliged
him to exercise a higher degree of diligence by scrutinizing the certificates of title and examining all factual circumstances in order to
determine the seller’s title and capacity to transfer any interest in the lots.