Documente Academic
Documente Profesional
Documente Cultură
VALDEZ
G.R. No. 171531| 30 JANUARY 2009
HEIRS OF MARIA P. VALDEZ, (EMILIA V. YUMUL and VICTORIA
V. MOLINO), HEIRS OF SEVERINA P. TUGADE (ILUMINADA and
LEONORA P. TUGADE), HEIRS OF ETANG P. GATMIN (LUDIVINA
GUARANTEED HOMES, INC. v. G. DELA CRUZ by and through ALFONSO G. DELA CRUZ,
HILARIA G. COBERO and ALFREDO G. COBERO) and SIONY G.
TEPOL, by and through ELENA T. RIVAS and ELESIO TEPOL, JR.,
AS HEIRS OF DECEDENT PABLO PASCUA
Petition for review on certiorari of CA decision and resolution.
Justice Tinga
FACTS: CA reversed the order of RTC-Olongapo, which granted the motion to dismiss filed by
petitioner Guaranteed Homes.
From the annexes attached in the complaint, it was ascertained that the OCT
contained several annotations which showed that the property had been sold by
Pablo to Alejandria Marquinez and Resituto Morales.
Jorge Pascua, Sr., son of Cipriano filed a petition with RTC-Olongapo for the issuance
of a new owners duplicate of OCT No. 404, which was denied. The trial court held
that petitioner was already the owner of the subject property, noting that the failure
to annotate the subsequent property to it at the back of said OCT did not affect its
title to the property.
CA reversed and held that the respondents complaint for quieting of title had not yet
prescribed.
ISSUE: Whether petitioner is an innocent purchaser for value, i.e. there is no need to go beyond
the registered title of spouses Rodolfo.
HELD: Yes (there is no need for petitioner to go beyond the clean title presented to them).
Petition granted. CA decision reversed and set aside.
RATIO: The Court held that it is basic that a person dealing with registered property need not
go beyond, but only has to rely on, the title of his predecessor-in-interest. Since the
act of registration is the operative act to convey or affect the land insofar as third
persons are concerned, it follows that where there is nothing in the certificate of title
to indicate any cloud or vice in the ownership of the property, or any encumbrance
thereon, the purchaser is not required to explore farther than what the Torrens title
upon its face indicates in quest for any hidden defect or inchoate right that may
subsequently defeat his right thereto.
In the present case, it is enough that petitioner examined the latest certificate of title
issued in the name of spouses Rodolfo. The petitioner as purchaser is not bound by
the original certificate but only by the certificate of title of the person from whom he
had purchased the property.