GR 193517; (January, 2014) (Digest)
G.R. No. 193517 ; January 15, 2014
THE HEIRS OF VICTORINO SARILI, represented by CELSO A. SARILI, Petitioners, vs. PEDRO F. LAGROSA, represented by LOURDES LABIOS MOJICA, Respondent.
FACTS
Respondent Pedro Lagrosa, owner of a parcel of land in Caloocan City covered by TCT No. 55979, discovered during a visit to the Philippines that a new title, TCT No. 262218, had been issued in the name of spouses Victorino and Isabel Sarili. The transfer was based on a Deed of Absolute Sale dated February 16, 1978, purportedly executed by Lagrosa and his wife. Lagrosa filed a complaint for annulment of title, alleging the 1978 deed was a forgery and that he never sold the property.
The Sarilis claimed they were innocent purchasers for value. They asserted they bought the property in good faith from Ramon Rodriguez in 1992, who presented a Special Power of Attorney (SPA) allegedly executed by Lagrosa authorizing the sale. They denied involvement in the 1978 deed, suggesting a “fixer” might have fabricated it to facilitate the titling process. Victorino Sarili died during the proceedings and was substituted by his heirs, the petitioners.
ISSUE
Whether or not there was a valid conveyance of the subject property to the Sarilis, warranting the annulment of TCT No. 262218 and the reinstatement of Lagrosa’s original title.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, ruling there was no valid conveyance. The legal logic centered on the forgery of the foundational documents and the failure to prove the Sarilis were innocent purchasers for value.
The Court found the February 16, 1978 Deed of Absolute Sale was forged, as Lagrosa’s signature thereon was dissimilar to his genuine signature. This deed was the source document for the issuance of the Sarilis’ title, as evidenced by Isabel Sarili’s own Affidavit of Late Registration. Consequently, the derivative 1992 deed from Rodriguez to the Sarilis was also void, as Rodriguez had no valid authority to sell. The purported SPA in favor of Rodriguez was likewise declared forged after a comparison with Lagrosa’s authentic signature.
The Sarilis’ claim of being innocent purchasers for value failed. The Court emphasized that one who deals with registered land must trust the certificate of title and is not required to go beyond it, except when the party has actual knowledge of facts that should impel a reasonably cautious person to make further inquiry. Here, the Sarilis were put on inquiry notice. The 1978 deed lacked Lagrosa’s community tax certificate, a requisite for notarization, and the notarization itself was defective as it was done years after the purported signing. These irregularities should have prompted the Sarilis to investigate the vendor’s authority, which they did not do. Therefore, they could not invoke the protection accorded to innocent purchasers. The forged deeds being void, the Sarilis acquired no title, and Lagrosa’s original title was rightfully reinstated.