CA 8037; (June, 1949) (Digest)
G.R. No. L-8037, June 28, 1949
DIRECTOR OF LANDS and ALFONSO MARIANO, plaintiffs; ALFONSO MARIANO, plaintiff-appellant, vs. MAXIMIANO P. MARTIN and DATU MAMINTU LUMANTAG, defendants-appellees.
FACTS
Alfonso Mariano filed a homestead application over Lot No. 2931 in Cotabato in 1932. The Director of Lands granted him preferential rights in 1933. During cadastral proceedings later that year, the lot was initially declared public land, with homestead rights granted to other claimants (Ricardo Reyes and Gattoc). After they withdrew their claims, Datu Mamintu Lumantag claimed private ownership. The court, without notifying the Director of Lands, adjudicated the lot to Lumantag in May 1934. On December 18, 1933, while the decision was pending, Lumantag sold his rights to Maximiano P. Martin. Mariano filed a petition for review on the ground of fraud in May 1935. In March 1936, the court set aside its 1934 decision, declaring it void as to Lumantag’s private ownership. No appeal was taken from this order. Martin obtained a transfer certificate of title in his name in October 1935. Mariano later filed a complaint to annul Martin’s title.
ISSUE
Whether the transfer certificate of title issued to Maximiano P. Martin is valid and binding despite the court’s subsequent order setting aside the decree of registration in favor of his vendor, Lumantag.
RULING
No. The Supreme Court reversed the lower court’s dismissal and declared Martin’s title null and void. The court’s order setting aside the 1934 decree had become final and conclusive on the issue of fraud. Martin was a transferee pendente lite, having purchased the property while the litigation was pending (before the final decree). As such, under Rule 3, Section 20 of the Rules of Court, he stands in the shoes of his vendor and is bound by any judgment against the transferor. His good faith is immaterial, as the protection for an innocent purchaser for value applies only when the purchase is made after a final decree, upon which the purchaser relies. Martin acquired his interest before any final decree, with awareness of the pending litigation. He was ordered to surrender his title.
AI Generated by Armztrong.