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GR No. 172652

2014-11-26

LEONARDO-DE CASTRO, J.

As between two innocent persons, one of whom must suffer the consequences of a breach of trust, the one who made it possible by his act of confidence must bear the loss.[49] Evidently, it was the utmost trust and confidence reposed by Chiok to Nuguid that caused this entire debacle, dragging three banks into the controversy, and having their resources threatened because of an alleged default in a contract they were not privy to.

GR No. 183448

2014-06-30

SPS. DOMINADOR PERALTA AND OFELIA PERALTA v. HEIRS OF BERNARDINA ABALON

SERENO, C.J.

In Tenio-Obsequio v. Court of Appeals, [18] we explained the purpose of the Torrens system and its legal implications to third persons dealing with registered land, as follows: The main purpose of the Torrens system is to avoid possible conflicts of title to real estate and to facilitate transactions relative thereto by giving the public the right to rely upon the face of a Torrens certificate of title and to dispense with the need of inquiring further, except when the party concerned has actual knowledge of facts and circumstances that should impel a reasonably cautious man to make such further inquiry. Where innocent third persons, relying on the correctness of the certificate of title thus issued, acquire rights over the property, the court cannot disregard such rights and order the total cancellation of the certificate. The effect of such an outright cancellation would be to impair public confidence in the certificate of title, for everyone dealing with property registered under the Torrens system would have to inquire in every instance as to whether the title has been regularly or irregularly issued by the court. Every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and the law will in no way oblige him to go beyond the certificate to determine the condition of the property.

GR No. 164961

2014-06-30

HECTOR L. UY v. VIRGINIA G. FULE

BERSAMIN, J.

The petitioner concludes that the absence of any irregularities in the documents presented to him, coupled with the fact that it was Isabel Ronda, et al., not the respondents, who were then in the possession of the lots in dispute, clearly evinced to him that he did not have to look beyond the titles presented to him; that, consequently, he could not have been aware of the respondents' claim over the disputed lots;[29] that he should be deemed an innocent purchaser for value because the only time that he could have been charged with constructive notice of the respondents' claim to the lots in dispute was after the annotation of their adverse claim on the title of the lot, which they made five months after the sale to him;[30] and that according to Tenio-Obsequio v. Court of Appeals,[31] "the rule of law and justice that should apply in this case is that as between two innocent persons, one of whom must suffer the consequences of a breach of trust, the one who made it possible by his act of confidence must bear the loss. The right of the innocent purchaser for value must be respected and protected, even if the seller obtained his title through fraud."[32]

GR No. 174004

2013-10-09

VIRGILIO G. CAGATAO v. GUILLERMO ALMONTE

MENDOZA, J.

In this case, there has been no showing that Spouses Fernandez were aware of any irregularity in Carlos' title that would make them suspicious and cause them to doubt the legitimacy of Carlos' claim of ownership, especially because there were no encumbrances annotated on Carlos' title. At any rate, that is the proper subject of another action initiated for the purpose of questioning Carlos' certificate of title from which Spouses Fernandez derived their ownership because, otherwise, the title of Spouses Fernandez would become indefeasible. The reason for this is extensively explained in Tenio-Obsequio v. Court of Appeals:[31]

GR No. 175485

2011-07-27

CASIMIRO DEVELOPMENT CORPORATION v. RENATO L. MATEO

BERSAMIN, J.

The Government has adopted the Torrens system due to its being the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized. If a person purchases a piece of land on the assurance that the seller's title thereto is valid, he should not run the risk of being told later that his acquisition was ineffectual after all, which will not only be unfair to him as the purchaser, but will also erode public confidence in the system and will force land transactions to be attended by complicated and not necessarily conclusive investigations and proof of ownership. The further consequence will be that land conflicts can be even more abrasive, if not even violent. The Government, recognizing the worthy purposes of the Torrens system, should be the first to accept the validity of titles issued thereunder once the conditions laid down by the law are satisfied. [13]

GR Nos. 187912-14

2011-01-31

JOEY P. MARQUEZ v. SANDIGANBAYAN 5TH DIVISION

MENDOZA, J.

In this case, the defense interposed by the accused Marquez was that his signatures in the disbursement vouchers, purchase requests and authorizations were forged. It is hornbook rule that as a rule, forgery cannot be presumed and must be proved by clear, positive and convincing evidence[11] and the burden of proof lies on the party alleging forgery.[12]

GR No. 179543

2010-10-06

CAMPER REALTY CORP. v. MARIA NENA PAJO-REYES

CARPIO MORALES, J.

A forged deed can legally be the root of a valid title when an innocent purchaser for value intervenes.[12] For a prospective buyer of a property registered under the Torrens system need not go beyond the title, especially when he has no notice of any badge of fraud or defect that would place him on guard.[13] His rights are thus entitled to full protection, for the law considers him an innocent purchaser.

GR No. 182673

2009-10-05

AQUALAB PHILIPPINES v. HEIRS OF MARCELINO PAGOBO

VELASCO JR., J.

The trial court ruled that prescription has set in, since respondents alleged in the complaint fraud and misrepresentation in procuring the transfer of subject lots, and such transfer was made on April 21, 1970, while the instant complaint was filed only on August 10, 1994, or a little over 24 years. Relying on Buenaventura v. Court of Appeals,[25] where the Court held that an action for reconveyance of title due to fraud is susceptible to prescription either within four or 10 years, the trial court held that the instant action is definitely barred. It also ruled that even if a constructive trust was created as averred by respondents, still, the instant action has prescribed for a constructive trust prescribes in 10 years, relying on Tenio-Obsequio v. Court of Appeals.[26]

GR NO. 133110

2007-03-28

BARSTOWE PHILIPPINES CORPORATION v. REPUBLIC

CHICO-NAZARIO, J.

However, BPC maintains that it was a purchaser in good faith, for value and without any inkling about any flaw from Servando's titles. It points out that it purchased the subject lots from Servando on 8 February 1989 and registered the same on 19 February 1991, way before the titles of Servando were declared null by the RTC on 22 December 1992. BPC relies on this Court's ruling in Tenio-Obsequio v. Court of Appeals,[56] to wit -

GR NO. 150736

2005-04-29

VIRGILIO MACASPAC v. RUPERTO PUYAT

CALLEJO, SR., J.

Moreover, defendant-appellant herein is already a holder of a Certificate of Land Ownership Award. The logical conclusion would be in favor of the continuous possession of appellant Virgilio Macaspac, who, having been found to be in actual possession and cultivation of the landholding, was accordingly issued a CLOA covering the same.[18] We agree with the DARAB. A person is presumed to take ordinary care of his concerns,[19] private transactions are presumed fair and regular and that ordinary course of business has been followed.[20] Moreover, in Tenio-Obsequio v. Court of Appeals,[21] the Court held that forgery cannot be presumed. A public document is evidence of the facts in the clear unequivocal manner therein expressed. It has in its favor the presumption of regularity.[22] Thus, he who alleges forgery must prove the same by clear, positive and convincing evidence.[23]

GR No. 149912

2004-01-29

JACINTO V. CO v. RIZAL MILITAR

YNARES-SATIAGO, J.

In Tenio-Obsequio v. Court of Appeals,[14] it was held that the Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.

AM No. MTJ 94-995

2002-09-05

LUZ ALFONSO v. ROSE MARIE ALONZO-LEGASTO

CORONA, J.

therefore admissible public documents, as respondents themselves would stipulate.[55] "In the case of public documents, the mere production of an admissible copy is generally sufficient to satisfy any requirement of proof of due execution of the document, in accordance with the maxim omnia praesumuntur rite et solemniter esse acta."[56] Accordingly, respondent Garcia is presumed to be the author of Exhs. "M," "N" and "O" purposely to falsify or cover up the fact that she was not reporting for work for two-and-a-half (2-1/2) months.[57] While this presumption may be rebutted, it may only be done by clear, strong and convincing evidence.[58] Respondent Garcia was not able to rebut this presumption. Her defense was mere unsubstantiated denial[59] which of course is a weak defense. Furthermore, if we are to compare the signatures on Exhs. "M," "N" and "O" with the admitted standard signatures

	GR No. 172652 2014-11-26	METROPOLITAN BANK v. WILFRED N. CHIOK LEONARDO-DE CASTRO, J.
As between two innocent persons, one of whom must suffer the consequences of a breach of trust, the one who made it possible by his act of confidence must bear the loss.[49] Evidently, it was the utmost trust and confidence reposed by Chiok to Nuguid that caused this entire debacle, dragging three banks into the controversy, and having their resources threatened because of an alleged default in a contract they were not privy to.
	GR No. 183448 2014-06-30	SPS. DOMINADOR PERALTA AND OFELIA PERALTA v. HEIRS OF BERNARDINA ABALON SERENO, C.J.
In Tenio-Obsequio v. Court of Appeals, [18] we explained the purpose of the Torrens system and its legal implications to third persons dealing with registered land, as follows: The main purpose of the Torrens system is to avoid possible conflicts of title to real estate and to facilitate transactions relative thereto by giving the public the right to rely upon the face of a Torrens certificate of title and to dispense with the need of inquiring further, except when the party concerned has actual knowledge of facts and circumstances that should impel a reasonably cautious man to make such further inquiry. Where innocent third persons, relying on the correctness of the certificate of title thus issued, acquire rights over the property, the court cannot disregard such rights and order the total cancellation of the certificate. The effect of such an outright cancellation would be to impair public confidence in the certificate of title, for everyone dealing with property registered under the Torrens system would have to inquire in every instance as to whether the title has been regularly or irregularly issued by the court. Every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and the law will in no way oblige him to go beyond the certificate to determine the condition of the property.
	GR No. 164961 2014-06-30	HECTOR L. UY v. VIRGINIA G. FULE BERSAMIN, J.
The petitioner concludes that the absence of any irregularities in the documents presented to him, coupled with the fact that it was Isabel Ronda, et al., not the respondents, who were then in the possession of the lots in dispute, clearly evinced to him that he did not have to look beyond the titles presented to him; that, consequently, he could not have been aware of the respondents' claim over the disputed lots;[29] that he should be deemed an innocent purchaser for value because the only time that he could have been charged with constructive notice of the respondents' claim to the lots in dispute was after the annotation of their adverse claim on the title of the lot, which they made five months after the sale to him;[30] and that according to Tenio-Obsequio v. Court of Appeals,[31] "the rule of law and justice that should apply in this case is that as between two innocent persons, one of whom must suffer the consequences of a breach of trust, the one who made it possible by his act of confidence must bear the loss. The right of the innocent purchaser for value must be respected and protected, even if the seller obtained his title through fraud."[32]
	GR No. 174004 2013-10-09	VIRGILIO G. CAGATAO v. GUILLERMO ALMONTE MENDOZA, J.
In this case, there has been no showing that Spouses Fernandez were aware of any irregularity in Carlos' title that would make them suspicious and cause them to doubt the legitimacy of Carlos' claim of ownership, especially because there were no encumbrances annotated on Carlos' title. At any rate, that is the proper subject of another action initiated for the purpose of questioning Carlos' certificate of title from which Spouses Fernandez derived their ownership because, otherwise, the title of Spouses Fernandez would become indefeasible. The reason for this is extensively explained in Tenio-Obsequio v. Court of Appeals:[31]
	GR No. 175485 2011-07-27	CASIMIRO DEVELOPMENT CORPORATION v. RENATO L. MATEO BERSAMIN, J.
The Government has adopted the Torrens system due to its being the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized. If a person purchases a piece of land on the assurance that the seller's title thereto is valid, he should not run the risk of being told later that his acquisition was ineffectual after all, which will not only be unfair to him as the purchaser, but will also erode public confidence in the system and will force land transactions to be attended by complicated and not necessarily conclusive investigations and proof of ownership. The further consequence will be that land conflicts can be even more abrasive, if not even violent. The Government, recognizing the worthy purposes of the Torrens system, should be the first to accept the validity of titles issued thereunder once the conditions laid down by the law are satisfied. [13]
	GR Nos. 187912-14 2011-01-31	JOEY P. MARQUEZ v. SANDIGANBAYAN 5TH DIVISION MENDOZA, J.
In this case, the defense interposed by the accused Marquez was that his signatures in the disbursement vouchers, purchase requests and authorizations were forged. It is hornbook rule that as a rule, forgery cannot be presumed and must be proved by clear, positive and convincing evidence[11] and the burden of proof lies on the party alleging forgery.[12]
	GR No. 179543 2010-10-06	CAMPER REALTY CORP. v. MARIA NENA PAJO-REYES CARPIO MORALES, J.
A forged deed can legally be the root of a valid title when an innocent purchaser for value intervenes.[12] For a prospective buyer of a property registered under the Torrens system need not go beyond the title, especially when he has no notice of any badge of fraud or defect that would place him on guard.[13] His rights are thus entitled to full protection, for the law considers him an innocent purchaser.
	GR No. 182673 2009-10-05	AQUALAB PHILIPPINES v. HEIRS OF MARCELINO PAGOBO VELASCO JR., J.
The trial court ruled that prescription has set in, since respondents alleged in the complaint fraud and misrepresentation in procuring the transfer of subject lots, and such transfer was made on April 21, 1970, while the instant complaint was filed only on August 10, 1994, or a little over 24 years. Relying on Buenaventura v. Court of Appeals,[25] where the Court held that an action for reconveyance of title due to fraud is susceptible to prescription either within four or 10 years, the trial court held that the instant action is definitely barred. It also ruled that even if a constructive trust was created as averred by respondents, still, the instant action has prescribed for a constructive trust prescribes in 10 years, relying on Tenio-Obsequio v. Court of Appeals.[26]
	GR NO. 133110 2007-03-28	BARSTOWE PHILIPPINES CORPORATION v. REPUBLIC CHICO-NAZARIO, J.
However, BPC maintains that it was a purchaser in good faith, for value and without any inkling about any flaw from Servando's titles. It points out that it purchased the subject lots from Servando on 8 February 1989 and registered the same on 19 February 1991, way before the titles of Servando were declared null by the RTC on 22 December 1992. BPC relies on this Court's ruling in Tenio-Obsequio v. Court of Appeals,[56] to wit -
	GR NO. 150736 2005-04-29	VIRGILIO MACASPAC v. RUPERTO PUYAT CALLEJO, SR., J.
Moreover, defendant-appellant herein is already a holder of a Certificate of Land Ownership Award. The logical conclusion would be in favor of the continuous possession of appellant Virgilio Macaspac, who, having been found to be in actual possession and cultivation of the landholding, was accordingly issued a CLOA covering the same.[18] We agree with the DARAB. A person is presumed to take ordinary care of his concerns,[19] private transactions are presumed fair and regular and that ordinary course of business has been followed.[20] Moreover, in Tenio-Obsequio v. Court of Appeals,[21] the Court held that forgery cannot be presumed. A public document is evidence of the facts in the clear unequivocal manner therein expressed. It has in its favor the presumption of regularity.[22] Thus, he who alleges forgery must prove the same by clear, positive and convincing evidence.[23]
	GR No. 149912 2004-01-29	JACINTO V. CO v. RIZAL MILITAR YNARES-SATIAGO, J.
In Tenio-Obsequio v. Court of Appeals,[14] it was held that the Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.
	AM No. MTJ 94-995 2002-09-05	LUZ ALFONSO v. ROSE MARIE ALONZO-LEGASTO CORONA, J.
therefore admissible public documents, as respondents themselves would stipulate.[55] "In the case of public documents, the mere production of an admissible copy is generally sufficient to satisfy any requirement of proof of due execution of the document, in accordance with the maxim omnia praesumuntur rite et solemniter esse acta."[56] Accordingly, respondent Garcia is presumed to be the author of Exhs. "M," "N" and "O" purposely to falsify or cover up the fact that she was not reporting for work for two-and-a-half (2-1/2) months.[57] While this presumption may be rebutted, it may only be done by clear, strong and convincing evidence.[58] Respondent Garcia was not able to rebut this presumption. Her defense was mere unsubstantiated denial[59] which of course is a weak defense. Furthermore, if we are to compare the signatures on Exhs. "M," "N" and "O" with the admitted standard signatures

OBSEQUIO v. CA