GR 105944; (February, 1996) (Digest)
G.R. No. 105944 ; February 9, 1996
SPOUSES ROMULO AND SALLY EDUARTE, petitioners, vs. THE HONORABLE COURT OF APPEALS and PEDRO CALAPINE (substituted by ALEXANDER CALAPINE and ARTEMIS CALAPINE), respondents.
FACTS
Pedro Calapine was the registered owner of a parcel of land. On April 26, 1984, he executed a deed of donation (donacion inter vivos) ceding one-half of the property to his niece, Helen Doria. Subsequently, a second deed dated July 26, 1984, purportedly executed by Calapine, donated the entire property to Doria. Based on this second deed, the original title was cancelled and a new Transfer Certificate of Title (TCT) was issued in Doria’s name. Doria later donated a portion to a church and sold the remainder to the spouses Romulo and Sally Eduarte.
Calapine filed a suit for revocation of the donation, claiming his signature on the second deed was forged and that Doria was unworthy of his liberality. He sought to annul the subsequent deeds and titles. The Regional Trial Court revoked the first donation, declared the second deed and the sale to the Eduarte spouses null and void, and ordered the cancellation of the derived titles, reinstating ownership in favor of Calapine’s substitutes. The Court of Appeals affirmed this decision, also declaring the Eduarte spouses as purchasers in bad faith.
ISSUE
Whether the Court of Appeals erred in affirming the revocation of the donation and in declaring the subsequent sale to the Eduarte spouses null and void, thereby ordering the cancellation of their title.
RULING
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The legal logic rests on the principle that a forged deed is void and produces no legal effect. Since the second deed of donation was found to be a forgery, it transferred no valid title to Helen Doria. Consequently, Doria had no ownership rights to convey to the Eduarte spouses. The sale was therefore void, and the TCT issued to the spouses derived from a void source must be cancelled.
The Court upheld the finding that the Eduarte spouses were purchasers in bad faith. Bad faith was established by their failure to exercise the diligence required of a prudent buyer. They purchased the property despite knowing Doria had only recently acquired it and without verifying the validity of her title or the circumstances of the donation from her uncle, the original owner. A purchaser in bad faith cannot invoke the protection of the law on registered titles. The revocation of the first donation was also proper due to the donee’s ingratitude and acts of defamation against the donor, which are grounds for revocation under the Civil Code. Thus, ownership was correctly restored to the heirs of the original donor.