G.R. No. 254046 , November 25, 2024.
Spouses Orencio S. Manalese and Eloisa B. Manalese, and Aries B. Manalese, Petitioners, vs. The Estate of the Late Spouses Narciso and Ofelia Ferreras, represented by its Special Administrator, Danilo S. Ferreras, Respondent.

FACTS

The properties in dispute are two parcels of land in Angeles City, originally registered under TCT Nos. 69711 and 69712 in the names of Spouses Narciso and Ofelia Ferreras. Narciso died in 2005 and Ofelia in 1992. Danilo Ferreras was appointed special administrator of their estate. Danilo filed an ejectment case against Carina Pinpin, who was occupying the properties by mere tolerance. The MTC ruled in favor of the estate and issued a writ of execution. Before execution, petitioners (Spouses Manalese and their son Aries) filed an injunction case to stop the writ, revealing they had acquired titles to the properties (TCT Nos. 198220 and 198221 in the names of Eloisa and Aries).
Danilo discovered that Pinpin had obtained TCT Nos. 181052 and 181053 in her name based on a Deed of Absolute Sale dated May 11, 2009, purportedly executed by the Spouses Ferreras. This was impossible as both spouses were already deceased. Pinpin had procured these titles by fraudulently filing an affidavit of loss for the owners’ duplicate certificates, which were actually in Danilo’s possession. Pinpin then sold the properties to petitioners via a Deed of Absolute Sale dated September 20, 2010.
The estate filed a complaint for annulment of titles and declaration of nullity of sale against petitioners and Pinpin. Petitioners claimed they were innocent purchasers for value, having bought the properties from Pinpin for PHP 750,000.00 after verifying her titles at the Registry of Deeds. The RTC ruled in favor of the estate, declaring all subsequent titles and deeds void and ordering the reinstatement of the original Ferreras titles. The Court of Appeals affirmed the RTC’s decision but deleted the award of damages. Petitioners filed the present Petition for Review.

ISSUE

Whether petitioners are innocent purchasers for value, such that their titles should be protected under the Torrens system.

RULING

No. Petitioners are not innocent purchasers for value. The Torrens system does not protect purchasers who buy registered land with knowledge of facts that should put them on inquiry about a defect in the title. The purported Deed of Absolute Sale from the Spouses Ferreras to Pinpin was dated May 11, 2009. A simple inquiry would have revealed that both registered owners were already deceased at that time (Ofelia died in 1992 and Narciso in 2005), rendering the sale a nullity. This fact was evident from the death certificates annotated on the titles. Petitioners’ failure to investigate this obvious and fatal defect constitutes gross negligence, making them buyers in bad faith. Since Pinpin acquired no valid title from the deceased owners, she could not transmit any valid title to petitioners. The principle of nemo dat quod non habet applies. Therefore, all subsequent titles (Pinpin’s and petitioners’) and the deeds of sale are void. The original certificates of title in the names of Spouses Ferreras (TCT Nos. 69711 and 69712) are reinstated. The Court affirmed the CA decision, which had affirmed the RTC’s annulment of the void titles and deeds.