Sunday, June 14, 2009

Reliance on Title

Furthermore, under the established principles of land registration, a person dealing with registered land may generally rely on the correctness of a certificate of title and the law will in no way oblige him to go beyond it to determine the legal status of the property, except when the party concerned has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry.

“Furthermore, he testified that he undertook great care in verifying the clean title of the said land, [e.g.,] deputizing an employee to do the necessary research, personally copying pertinent documents registered in the Registry of Property and even consulting legal advice on the matter. These, for Us, are badges of good faith.” (MCIAA v. Tirol, G.R. No. 171535, June 5, 2009)

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.

In this case, when the subject properties were sold to Catalino Torre and subsequently to Doronila, respondent Jose was not in possession of the said properties. Such fact should have put the vendees on guard and should have inquired on the interest of the respondent Jose regarding the subject properties (Yared v. Tiongco, G.R. No. 161360. October 19, 2011).

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