GR 46724; (September, 1939) (Digest)
G.R. No. 46724 ; September 30, 1939
CRESCENCIO REYNES, ET AL., plaintiffs-appellees, vs. ROSALINA BARRERA, ET AL., defendants-appellants.
FACTS
The spouses Vidal Reynes and Lucia R. de Reynes owned a registered lot. Lucia died, leaving the plaintiffs (Cresencio Reynes, et al.) as her heirs. After her death, Vidal incurred a debt. In the ensuing court action, the lot was levied upon and sold at public auction to satisfy the judgment. Vidal’s brother, Manuel Reynes, redeemed the property. The lot was later subdivided, and Manuel obtained a transfer certificate of title for one portion (Lot No. 471-b). Manuel then sold this lot under a pacto de retro to the defendant, Rosalina Barrera, who later acquired full ownership. The plaintiffs, as Lucia’s heirs, sued to annul the auction sale of their hereditary half-interest and all subsequent transfers, claiming the sale was void as to their share. The trial court ruled in favor of the plaintiffs.
ISSUE
Whether a purchaser in good faith and for value of registered land under the Torrens system acquires valid title, despite a potential defect in the title of her predecessor-in-interest (Manuel Reynes) arising from a prior judicial sale that may have been voidable as to the plaintiffs’ hereditary share.
RULING
Yes. The Supreme Court reversed the trial court’s decision and absolved defendant Barrera. The Court held that where the subject of a judicial sale is registered land, a purchaser in good faith and for value is entitled to rely on the face of the Torrens certificate of title and is not required to look beyond it for any hidden defects. Barrera purchased the property from Manuel Reynes, whose certificate of title showed no encumbrance or vice. Under Section 39 of the Land Registration Act ( Act No. 496 ), a purchaser in good faith holds the title free from all encumbrances except those noted on the certificate. The principle of indefeasibility of a Torrens title protects an innocent purchaser for value, and her title cannot be annulled even if the registration of her predecessor was allegedly flawed.
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