G.R. No. 165114 ; August 6, 2008
Republic of the Philippines, petitioner, vs. Mabelle Ravelo and Spouses Emmanuel and Perlita Redondo, respondents.

FACTS

The Republic, through the DENR, sought the cancellation of Sales Patent No. 12458 and the corresponding Original Certificate of Title (OCT) issued to respondent Mabelle Ravelo over a parcel of land in Olongapo City. The government alleged the patent was void, having been issued by the Director of Lands in Manila in violation of DENR Administrative Order No. 20, which required applications to be filed with the regional office having territorial jurisdiction. The government also alleged fraud, claiming Ravelo misrepresented the land as unoccupied public domain. A notice of lis pendens for the reversion case was annotated on Ravelo’s title on March 24, 1994.
Prior to this annotation, Ravelo’s title was levied upon due to a money judgment against her. The property was sold at public auction to Wilson Chieng on May 25, 1993. Subsequently, respondent-spouses Emmanuel and Perlita Redondo, who owned the adjacent lot, purchased the property from Chieng. The parties had a purchase agreement dated May 11, 1993, and a deed of absolute sale was executed on December 20, 1993. The final deed to Chieng was inscribed and his Transfer Certificate of Title (TCT) was issued on September 23, 1994, which carried over the lis pendens annotation. The Redondos’ TCT was issued on December 20, 1994. The trial court ordered the cancellation of all titles and reversion of the land to the public domain.

ISSUE

Whether the respondent-spouses Redondo are innocent purchasers for value whose title is protected against the Republic’s action for reversion based on a void patent.

RULING

Yes, the Supreme Court affirmed the Court of Appeals and upheld the Redondos’ title. The Court ruled that a purchaser in good faith and for value acquires valid title even if the source title was void, provided the acquisition occurred before a notice of lis pendens was annotated. The pivotal facts are that the Redondos entered into a purchase agreement with Chieng on May 11, 1993, and paid the purchase price under a deed dated December 20, 1993. The notice of lis pendens for the reversion suit was only annotated on March 24, 1994. Therefore, the Redondos’ rights as buyers accrued and were perfected prior to any constructive notice of the suit challenging the root title.
The legal logic is anchored on the principle of indefeasibility of a Torrens title and the protection afforded to innocent purchasers. A void title may still be the source of a valid title in the hands of an innocent purchaser for value. The Court emphasized that the Redondos had no actual knowledge of the patent’s alleged invalidity, and they were not bound to look beyond the face of Chieng’s TCT, which was clean at the time of their purchase. The subsequent annotation of the lis pendens on the title did not affect their already vested rights. The government’s claim that the sale violated the alienation restrictions under the Public Land Act was also rejected, as Presidential Decree No. 2004 had removed such restrictions. Consequently, the reversion action could not prevail against the Redondos’ indefeasible title.