GR 23197; (May, 1977) (Digest)
G.R. No. L-23197 May 26, 1977
PEDRO PASCUA, LUISA CORPUZ, ANDRES PASCUA, VICTORIANO PASCUA and BONIFACIA LORA, plaintiffs-appellees, vs. MARIANO COPUYOC, QUINTIN MELEBO, MARTA MANUEL, PEDRO PASCUA, SEVERINA PASCUA, ANGELO REYES, FLAVIANO BALTAZAR and THE INSULAR TREASURER, defendants-appellants.
FACTS
The property in dispute is Lot No. 2986 of the Guimba Cadastral Survey. The evidence established a clear chain of ownership originating from Juan Pascua, who cleared the land before the Philippine Revolution. In 1900, the property was ceded to spouses Victoriano Pascua and Bonifacia Lora. Victoriano exercised exclusive proprietary rights, paying taxes and having the lot surveyed in 1920. Subsequently, Victoriano and Bonifacia sold one-half of the lot to their son Andres Pascua in 1929 and donated the other half to their son Pedro Pascua (married to Luisa Corpuz) in 1936. These transactions were duly registered. However, a 1929 cadastral court decision erroneously awarded the lot to the “heirs of Juan Pascua,” naming specific individuals including a different “Pedro Pascua” (married to Marcelina Ancheta). Upon discovery, the true owners, Pedro and Andres Pascua, filed a petition for review. Several named heirs in the erroneous decision executed instruments recognizing the rights of Pedro and Andres Pascua to the entire property.
Despite the pending petition for review, Marta Manuel, an heir of Victoriano, filed an ex-parte motion in 1952 for the issuance of a decree based on the 1929 decision. The decree was issued, leading to the issuance of Original Certificate of Title No. O-680. Through a series of rapid transactions in 1952 and 1953 before the same notary public, Marta Manuel acquired interests from some of the named heirs in the 1929 decision. She then sold a 6/7 interest to Quintin Melebo, who subsequently conveyed it to Mariano Copuyoc. Title was thus issued in the names of Copuyoc (6/7) and Victoriano Pascua (1/7).
ISSUE
Whether the registered title of appellant Mariano Copuyoc can be assailed, and whether reconveyance of the property to the true owners is proper.
RULING
Yes, the title can be assailed, and reconveyance is proper. The Supreme Court affirmed the trial court’s judgment ordering Copuyoc to reconvey the lot to appellees Pedro and Andres Pascua. The Court adopted the trial court’s exhaustive findings, which concluded that fraud and deceit attended the procurement of the decree and the subsequent titles. The legal logic rests on the principle that a Torrens title, while indefeasible, does not shield a holder who acquired it through fraud or who is not a purchaser in good faith. The Court found that the circumstances surrounding the issuance of the decree and the subsequent transactions were highly suspicious. The ex-parte motion was filed while a petition for review was pending, and the rapid series of conveyances involving an illiterate party (Marta Manuel) suggested a scheme to circumvent the true ownership.
The Court emphasized that the Torrens system does not relieve a party dealing with registered land from the duty to make a proper inquiry when extant circumstances suggest a flaw in the registered owner’s rights. The appellants, particularly through their counsel, were charged with knowledge of these circumstances, including the pending petition and the prior recognized instruments from the other heirs. Therefore, Copuyoc could not be considered
