GR 234533; (June, 2018) (Digest)
G.R. No. 234533 June 27, 2018
SPOUSES JULIETA B. CARLOS and FERNANDO P. CARLOS, Petitioners vs. JUAN CRUZ TOLENTINO, Respondent
FACTS
Respondent Juan Cruz Tolentino filed a complaint for annulment of title against his wife Mercedes, grandson Kristoff, and petitioners Spouses Carlos. The subject was a parcel of land registered under Juan’s name. Without Juan’s knowledge, Mercedes and Kristoff allegedly forged a Deed of Donation, making it appear Juan and Mercedes donated the property to Kristoff. A new title was issued in Kristoff’s name. Kristoff then sold the property to petitioner Julieta Carlos. The sale was negotiated through Julieta’s brother, and a Memorandum of Agreement and subsequent Deed of Absolute Sale were executed, with full payment made by June 30, 2011. Juan discovered the forgery and annotated an adverse claim on the title on July 15, 2011. A second Deed of Absolute Sale was later executed, and a new title was issued to the Spouses Carlos, carrying over Juan’s adverse claim.
ISSUE
Whether the Spouses Carlos are innocent purchasers for value, thereby validating their title over the disputed property despite the forged donation.
RULING
No, the Spouses Carlos are not innocent purchasers for value. The Supreme Court affirmed the Court of Appeals’ reversal of the RTC decision. The legal logic hinges on the nature of the property and the buyers’ failure to exercise due diligence. The property was conjugal, acquired during the marriage of Juan and Mercedes. A forged donation is void and conveys no title; thus, Kristoff acquired no rightful ownership to sell. Consequently, the Spouses Carlos could not acquire better rights than their predecessor.
Crucially, the petitioners failed to act as prudent buyers. They negotiated solely through Julieta’s brother and relied on Kristoff’s documents without verifying the source of his title or the circumstances of the donation from his grandparents, with whom he resided. Their failure to conduct a simple investigation or personally inquire from the registered owners, Juan and Mercedes, constituted gross negligence, disqualifying them from the protection accorded to innocent purchasers for value. The annotation of the adverse claim after the sale but before the issuance of their title further charged them with notice of the defect. Therefore, the subsequent title issued to them is void, and the property must be reconveyed to Juan.