Philippine National Bank, Petitioner, vs.

Spouses Bernard and Cresencia Maranon, Respondents

G.R. No. 189316, July 01, 2013
Facts: The case is a petition for review on certiorari under Rule 45 of the Rules of Court. The antecedent
events being the Spouses Maranon, owner of a piece of real property, erected with a building occupied by
various tenants. Said subject property was among the properties mortgaged by spouses Montealegre to
PNB as a security for a loan. Spouses Montealegre, through a falsified Deed of Sale, acquired title to the
property and used the propertys title which was purportedly registered in the name of Emelie
Montealegre. However, due to failure to pay the loan, said property was foreclosed by PNB, and upon
auction, was thereafter acquired by the same bank, PNB. Spouses Maranon filed before the RTC a
complaint for Annulment of Title, Reconveyance and Damages against spouses Montealegre. Judgment of
RTC was rendered in favour of spouses Maranon, and also stipulated that the Real Estate Mortgage lien
of PNB shall stay and be respected. Such decision prompted PNB to also seek for entitlement to the fruits
of the property such as rentals paid by the tenants.
Issue: Whether or not is PNB entitled to fruits of the disputed property.
Ruling: No. Rent is a civil fruit that belongs to the owner of the property producing it by right of
accession. The rightful recipient of the disputed rent in this case should be thus the owner of the lot at the
time the rent accrued. It is beyond question that spouses Maranon never lost ownership over the subject
lot, and that technically, there is no juridical tie created by a valid mortgage contract that binds PNB to the
subject lot because the mortgagors Montealegre were not the true owners. PNBs lien as a mortgagee in
good faith pertains to the subject lot alone and not on the erected building which was not foreclosed and
still remained to be a property of Maranon. Thus, PNBs claim for the rents paid by the tenants has no
basis.

Spouses Alfonso and Maria Angeles Cusi, Petitioners, vs. Lilia V. Domingo,Respondent.
G.R. No. 195825; February 27, 2013
Ramona Liza L. De Vera, Petitioner, vs. Lilia V. Domingo and Spouses Radella and Alfred
Sy, Respondents
G.R. No. 195871
Facts: Lilia Domingo owned a certain real property which was vacant and unfenced. After some time, a
construction activities were being undertaken on her property without her knowledge and more so,
without her consent. She soon was able to discover a series of anomalous transactions involving her
property. It turned out that Radella Sy was able to execute a falsified deed of sale and thereafter, acquired
a valid title to the property. Sy then divided the property into two and sold each half to spouses De Vera
and Spouses Cusi, and both buyers were able to have valid titles to the property on their names. All of the
said transactions took place without the knowledge of the real owner Lilia Domingo. Upon learning of the
circumstances, Domingo filed a case at the RTC seeking annulment or cancellation of the titles issued.
The RTC rendered a decision, affirmed by the CA in favor of Lilia Domingo.
Issue: What is the effect of acquiring a real property under the Torrens System of Land Registration?
Ruling: Under the Torrens system of land registration, the State is required to maintain a register of
landholdings that guarantees indefeasible title to those included in the register. The State issues an official

certificate of title to attest to the fact that the person named is the owner of the property described therein,
subject to such liens and encumbrances as thereon noted or what the law warrants or reserves. One of the
guiding tenets underlying the Torrens system is the curtain principle, in that one does not need to go
behind the certificate of title because it contains all the information about the title of its holder. This
principle dispenses with the need of proving ownership by long complicated documents kept by the
registered owner, which may be necessary under a private conveyancing system, and assures that all the
necessary information regarding ownership is on the certificate of title. Consequently, the avowed
objective of the Torrens system is to obviate possible conflicts of title by giving the public the right to rely
upon the face of the Torrens certificate and, as a rule, to dispense with the necessity of inquiring further;
on the part of the registered owner, the system gives him complete peace of mind that he would be
secured in his ownership as long as he has not voluntarily disposed of any right over the covered land.
The petitioners were shown to have been deficient in their vigilance as buyers of the property. It
was not enough for them to show that the property was unfenced and vacant; otherwise, it would be too
easy for any registered owner to lose her property, including its possession, through illegal occupation. In
view of the foregoing, the court affirmed the decision of the lower courts and restores to Domingo her
rights of dominion over the property.