G.R. No. 84201, August 3, 1990
NORMA S. TIRADO, petitioner, vs. LILIA SEVILLA, THOMAS S. ONG, CELSO UY and THE COURT OF APPEALS, respondents.

FACTS

Petitioner Norma Tirado owned a parcel of land acquired from her father. She engaged respondent Lilia Sevilla to assist in titling the property, with an agreement for Sevilla to purchase a portion. Sevilla failed to fulfill her obligations. Instead, without Tirado’s knowledge, Sevilla filed a petition and secured a Transfer Certificate of Title (TCT No. 4128) over the entire land, which included Tirado’s portion. Sevilla subsequently subdivided the property and obtained new titles in her name. She then sold portions of the land covered by TCT No. C-10299 to respondents Thomas Ong and Celso Uy, who were issued TCT No. C-12456.
Tirado filed an action for annulment of the judgment that led to Sevilla’s title and for cancellation of the derived certificates. The Regional Trial Court ruled in Tirado’s favor, declaring null and void the titles derived from TCT No. 4128, including those of Ong and Uy, and ordering Sevilla to reimburse them. On appeal, the Court of Appeals modified the decision, declaring Ong and Uy as purchasers in good faith and for value, thereby upholding the validity of TCT No. C-12456 in their names. Tirado filed this petition for review.

ISSUE

Whether respondents Ong and Uy are purchasers in good faith and for value, such that their title (TCT No. C-12456) is valid and indefeasible.

RULING

The Supreme Court affirmed the Court of Appeals, ruling that Ong and Uy were purchasers in good faith. The legal logic centers on the principles of indefeasibility of a Torrens title and the protection afforded to innocent purchasers for value. When Ong and Uy purchased the property from Sevilla in 1977, they relied on TCT No. C-10299, which was clean and in Sevilla’s name. While a notice of lis pendens had been annotated on the mother title (TCT No. 4128) by Tirado in 1976, this title had already been cancelled and replaced by TCT No. C-10299, which was free from any such annotation at the time of the sale.
The Court emphasized that a purchaser is not required to look beyond the vendor’s certificate of title. Ong and Uy had no duty to investigate the history of the title beyond what was presented. The subsequent annotation of lis pendens by Tirado on TCT No. C-10298 (a separate title) in 1979 and on TCT No. C-12456 in 1980 was irrelevant, as these acts occurred after the sale and issuance of title to Ong and Uy in 1977 and 1978, respectively. By the time Tirado impleaded them in 1980, TCT No. C-12456 had already become indefeasible after the lapse of the one-year period from its issuance. Consequently, as innocent purchasers for value who relied on a clean title, Ong and Uy’s ownership is protected. The proper recourse for Tirado is a separate action for reimbursement against Sevilla.