GR L 30162; (September, 1987) (Digest)
G.R. No. L-30162 August 31, 1987
CANDIDO FRANCISCO, petitioner, vs. THE COURT OF APPEALS, ONOFRE ESPIRITU, POTENCIANA ESPIRITU, FELIX ESPIRITU, RITA ESPIRITU, CASIMIRO ESPIRITU, and HEIRS OF DEOGRACIAS ESPIRITU, et al., respondents.
FACTS
Nicolasa Resurreccion owned three parcels of land under TCT No. 9045. On August 19, 1925, she sold Lots 3 and 9 to Agustin Esguerra, who then sold them to spouses Pedro Francisco and Francisca Tolentino. The Franciscos registered this sale under Act No. 3344 , declared the property for taxation, and possessed the lots. Their son, petitioner Candido Francisco, continued this possession. On August 16, 1928, Resurreccion executed another deed selling all three lots, including the already-sold Lots 3 and 9, to Felisa Afable. Afable registered the sale under the Torrens Act and obtained TCT No. 14256. Thirty-one years later, on September 22, 1959, Afable sold the property to respondents, the Espiritus, who obtained TCT No. 70517. The Espiritus then demanded that Candido Francisco vacate Lots 3 and 9.
ISSUE
Whether the respondents, the Espiritus, are purchasers in good faith entitled to the protection of the Torrens system, thereby defeating the claim of petitioner Candido Francisco.
RULING
No. The Supreme Court reversed the Court of Appeals and ruled in favor of Candido Francisco. The legal logic centers on the failure of the Espiritus to qualify as purchasers in good faith. While a Torrens title is generally indefeasible, this protection extends only to innocent purchasers for value. The Court found that the Espiritus were not in good faith because they failed to exercise the requisite diligence before their purchase. They admitted visiting the property before buying it and seeing Francisco’s house on the disputed lots. This visible, adverse possession for over thirty years imposed a duty upon them to investigate the nature of Francisco’s claim. Their failure to make such a reasonable inquiry is, in law, a want of good faith. Knowledge of such possession is equivalent to registration of the adverse claim. Consequently, they cannot invoke their Torrens title to defeat the rights of Francisco, whose and his predecessors’ good faith and long-standing possession were never questioned. The Court ordered the respondents to reconvey Lots 3 and 9 to Francisco.