GR L 13971; (February, 1961) (Digest)
G.R. No. L-13971. February 27, 1961. CARLOS MAÑACOP, JR., plaintiff-appellant, vs. FAUSTINO CANSINO, defendant-appellee.
FACTS
The dispute involves a parcel of land in Cuyapo, Nueva Ecija, originally covered by a homestead patent and title in the name of Sabina Tomas. Between 1920 and 1923, Tomas sold portions of the land to spouses Bartolome Ancheta and spouses Faustino Cansino. These portions were subsequently adjudicated to them in cadastral proceedings, resulting in the issuance of separate original certificates of title: OCT No. 3885 for the Anchetas (Lot 342) in 1925 and OCT No. 4742 for the Cansinos (Lot 387) in 1925. The Anchetas later sold their lot to the Cansinos in 1937, consolidating ownership under TCT No. 13591.
After Sabina Tomas’s death in 1952, her heirs, Juliana and Clodualdo Dagdag, procured a new duplicate of Tomas’s old title (TCT No. 99) in 1953, executed an extrajudicial partition, and obtained a new title (TCT No. NT-14970) in their names. They then sold the entire land to Benito Bringas in 1955, who secured a title (TCT No. NT-18797), and Bringas subsequently sold it to Carlos Mañacop, Jr. in 1956, who obtained TCT No. NT-20508. Mañacop then filed an action to recover possession from Faustino Cansino, who had been in continuous possession since his purchase in the 1920s.
ISSUE
Whether the plaintiff, Carlos Mañacop, Jr., is a purchaser in good faith whose Torrens title should prevail over the long-standing possession and claim of ownership by the defendant, Faustino Cansino.
RULING
The Supreme Court affirmed the trial court’s decision in favor of Cansino, declaring his title superior and ordering the cancellation of Mañacop’s certificate of title. The Court held that Mañacop could not be considered a purchaser in good faith. The legal logic rests on the principle that a transferee of registered land who has knowledge of facts that would prompt a reasonably prudent person to inquire into the status of the title cannot invoke the protective mantle of the Torrens system as an innocent purchaser for value.
The record established that approximately nine months before his purchase, Mañacop visited the land and was informed by an individual named Abdon that Cansino was cultivating it and that he (Mañacop) could not possibly work on it. Mañacop relayed this information to his vendor, Bringas, who did not deny it. This constituted actual notice of Cansino’s adverse, open, and continuous possession spanning decades. Such possession served as a warning that the title derived from the heirs of Sabina Tomas, which was subject to the claims of persons unduly deprived under Rule 74, Section 4 of the Rules of Court, was potentially flawed. By proceeding with the purchase despite this knowledge, Mañacop assumed the risk. Consequently, his title, though registered, was not acquired in good faith and must yield to Cansino’s superior claim rooted in prior purchase, judicial adjudication, and uninterrupted possession. The Court found it unnecessary to resolve the procedural issue regarding the applicable prescriptive period under Rule 74, as the finding of bad faith was dispositive.