GR L 23268; (June, 1972) (Digest)
G.R. No. L-23268 June 30, 1972
PASTOR B. CONSTANTINO and PASTOR CONSTANTINO, JR., plaintiffs-movants-appellees, vs. HERMINIA ESPIRITU, defendant, NICANOR B. AVES, purchaser-oppositor-appellant.
FACTS
Plaintiffs filed a case against Herminia Espiritu concerning a parcel of land, resulting in the annotation of a notice of lis pendens on the title. The lower court initially dismissed the complaint. While the plaintiffs’ petition for mandamus to compel approval of their record on appeal was still pending before the Supreme Court, Espiritu secured the cancellation of the lis pendens annotation from the Register of Deeds by presenting the dismissal order. Relying on the clean title, Nicanor B. Aves subsequently purchased the property from Espiritu, and a new title was issued in his name. After the Supreme Court granted the mandamus petition, the plaintiffs moved to have the cancelled lis pendens reinstated and annotated on Aves’s new title.
ISSUE
Whether an innocent purchaser for value, who relied on a certificate of title cleared of a lis pendens due to its prior cancellation by the Register of Deeds, can be bound by a subsequent judicial declaration that such cancellation was improper and illegal.
RULING
No. The Supreme Court reversed the lower court’s order, ruling in favor of appellant Aves. The legal logic is anchored on the principles of the Torrens system, which aims to protect bona fide purchasers for value. When Aves purchased the property, the title presented was free from the lis pendens annotation due to its prior cancellation. Aves had no duty to look beyond the certificate of title to investigate the propriety of that cancellation. The Court emphasized that the act of registration is the operative act to convey land under the Torrens system. Since Aves was an innocent purchaser for value who relied on the face of the clean title, his rights are protected. The subsequent judicial declaration of nullity of the cancellation does not retroactively impair his acquired rights. To hold otherwise would undermine the integrity and reliability of Torrens certificates of title, which are designed to be conclusive evidence of ownership.