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CASIMIRO DEVELOPMENT CORPORATION v. RENATO L. MATEO

This case has been cited 8 times or more.

	GR No. 206584 2016-01-11	MAE FLOR GALIDO v. NELSON P. MAGRARE CARPIO, J.
The parcels of land involved in this case are registered under the Torrens system. One who deals with property registered under the Torrens system need not go beyond the certificate of title, but only has to rely on the certificate of title.[44] Every subsequent purchaser of registered land taking a certificate of title for value and in good faith shall hold the same free from all encumbrances except those noted on said certificate and any of the encumbrances provided by law.[45]
	GR No. 179751 2015-08-05	HERMINIA L. MENDOZA v. SPS. ARMANDO BRION, J.
Register of Deeds In Casimiro Development Corporation v. Mateo,[41] the Court held that the presence of anything that excites or arouses suspicion should prompt the vendee to look beyond the certificate and to investigate the title of the vendor appearing on the face of said certificate.[42]
	GR No. 194077 2014-12-03	FLORENTINO W. LEONG v. EDNA C. SEE LEONEN, J.
The Torrens system was adopted to "obviate possible conflicts of title by giving the public the right to rely upon the face of the Torrens certificate and to dispense, as a rule, with the necessity of inquiring further."[57]
	GR No. 194077 2014-12-03	FLORENTINO W. LEONG v. EDNA C. SEE LEONEN, J.
One need not inquire beyond the four corners of the certificate of title when dealing with registered property.[58] Section 44 of Presidential Decree No. 1529 known as the Property Registration Decree recognizes innocent purchasers in good faith for value and their right to rely on a clean title: Section 44. Statutory liens affecting title. - Every registered owner receiving a certificate of title in pursuance of a decree of registration, and every subsequent purchaser of registered land taking a certificate of title for value and in good faith, shall hold the same free from all encumbrances except those noted in said certificate and any of the following encumbrances which may be subsisting, namely:
	GR No. 204369 2014-09-17	ENRIQUETA M. LOCSIN v. BERNARDO HIZON VELASCO JR., J.
The CA, however, affirmed the RTC's finding that herein respondents are innocent purchasers for value. Citing Casimiro Development Corp. v. Renato L. Mateo,[7]the appellate court held that respondents, having dealt with property registered under the Torrens System, need not go beyond the certificate of title, but only has to rely on the said certificate. Moreover, as the CA added, any notice of defect or flaw in the title of the vendor should encompass facts and circumstances that would impel a reasonably prudent man to inquire into the status of the title of the property in order to amount to bad faith.
	GR No. 205879 2014-04-23	SKUNAC CORPORATION v. ROBERTO S. SYLIANTENG PERALTA, J.
It is true that a person dealing with registered land need not go beyond the title. However, it is equally true that such person is charged with notice of the burdens and claims which are annotated on the title.[38] In the instant case, The Torrens Certificate of Title (TCT No. 5760-R) in the name of Romeo, which was the title relied upon by petitioners, also contained Entry No. P.E. 4023, quoted above, which essentially informs petitioners that the lots which they were about to buy and which they in fact bought, were already sold to Emerenciana.[39] This entry should have alerted petitioners and should have prodded them to conduct further investigation. Simple prudence would have impelled them as honest persons to make deeper inquiries to clear the suspiciousness haunting Romeo's title. On the contrary, rather than taking caution in dealing with Romeo, petitioners, instead, subsequently executed deeds of sale[40] over the same properties but all of which were, nonetheless, disallowed by the estate court in its Order[41] dated October 11, 1993 on the ground that the said lots were already sold, this time, by Emerenciana to respondents. In this regard, petitioners acted in bad faith.
	GR No. 174004 2013-10-09	VIRGILIO G. CAGATAO v. GUILLERMO ALMONTE MENDOZA, J.
From the arguments of Cagatao, it is clear that he is assailing the validity of the title of Carlos over the land in question. Section 48 of P.D. No. 1529 clearly states that "a certificate of title shall not be subject to collateral attack. It cannot be altered, modified, or cancelled except in a direct proceeding in accordance with law." An attack on the validity of the title is considered to be a collateral attack when, in an action to obtain a different relief and as an incident of the said action, an attack is made against the judgment granting the title.[23] Cagatao's original complaint before the RTC was for the cancellation of TCT No. T-249437 in the name of the Fernandez Siblings and the nullification of the deeds of sale between the Fernandez Siblings and Spouses Fernandez, and the earlier one between the latter and Almonte and Aguilar. Nowhere in his complaint did Cagatao mention that he sought to invalidate TCT No. 12159-A. It was only during the course of the proceedings, when Spouses Fernandez disclosed that they had purchased the property from Carlos, that Cagatao thought of questioning the validity of TCT No. 12159-A.
	GR No. 173987 2013-02-25	PADILLA MERCADO v. SPS. AGUEDO ESPINA PERALTA, J.
Apropos to the foregoing, it bears to note at this stage that the Court likewise agrees with the ruling of the CA that respondents are presumed purchasers in good faith. In holding thus, the CA relied on the settled principle that one who deals with property registered under the Torrens System need not go beyond the same, but only has to rely on the title.[20] In the instant case, there is no dispute that the subject property was already covered by a Torrens title when respondents bought the same. There was no allegation in the Amended Complaint that respondents were not buyers in good faith. More particularly, there was nothing in the said complaint to indicate that respondents were aware of or were participants in the alleged fraud supposedly committed against petitioners' predecessor-in-interest, or that they have notice of any defect in the title of the seller. As the CA correctly noted, from the time that petitioners' predecessor-in-interest was supposedly deprived of ownership of the subject lot through an alleged fraudulent sale, the same had already been sold thrice. Moreover, since the subject property was already covered by a Torrens title at the time that respondents bought the same, the law does not require them to go beyond what appears on the face of the title. The lot has, thus, passed to respondents, who are presumed innocent purchasers for value, in the absence of any allegation to the contrary.