G.R. Nos. L-71490-91, June 28, 1988
ERNESTO BERNALES, et al. and ROMAN CATHOLIC BISHOP OF ABRA, petitioners, vs. INTERMEDIATE APPELLATE COURT, ELPIDIO SIAGAN, ALFONSO CADIAM, OGNAY CULLAWIT, respondents.

FACTS

The dispute concerns Lot No. 1494, originally public land. Petitioners trace their claim through Dagaoan Sawadan, who allegedly possessed the land since 1908. Her son, Augusto Siagan, inherited it. In 1967, Augusto’s son, Constante Siagan, sold the lot to the Pasimio spouses, who later sold it to the Roman Catholic Bishop of Bangued, Inc., which then sold it to the petitioner-tenants. Petitioners allege continuous possession as tenants and later as owners. Conversely, private respondents anchor their claim on Elpidio Siagan, another son of Henry Siagan. In 1967, Augusto and Elpidio executed a Memorandum of Agreement partitioning Henry Siagan’s estate, wherein Augusto quitclaimed Lot 1494 in favor of Elpidio. Relying on this, Elpidio obtained a Free Patent and an Original Certificate of Title (OCT No. P-392) in 1968. In 1973, Elpidio sold the titled lot to spouses Alfonso Cadiam and Ognay Cullawit, who received a Transfer Certificate of Title. When the Cadiam spouses took possession, petitioners forcibly dispossessed them, leading to consolidated civil cases for recovery of ownership.

ISSUE

The core issue is who has a superior right to Lot No. 1494: the petitioners, who claim under a series of unregistered sales from Constante Siagan, or the private respondents, who hold a Torrens title derived from Elpidio Siagan’s free patent.

RULING

The Supreme Court denied the petition and affirmed the Intermediate Appellate Court’s decision, ruling in favor of the private respondents. The legal logic rests on the principles of the Torrens system and the status of an innocent purchaser for value. Elpidio Siagan’s acquisition of a free patent and subsequent OCT No. P-392 is presumed regular. When he sold the property to the Cadiam spouses, who had no knowledge of any defect in the title and paid valuable consideration, they became innocent purchasers for value. Their TCT, issued under the Torrens system, is entitled to protection. In contrast, petitioners’ claim originates from Constante Siagan’s sale. The Court found Constante had no authority to sell, as ownership passed to his father, Augusto Siagan, who was alive in 1967 and had already quitclaimed the lot to Elpidio. A sale by a non-owner is void and conveys no title. The subsequent registrations by petitioners’ predecessors under Act No. 3344 do not prevail over a Torrens title, as such registration is expressly without prejudice to a third party with a better right. Here, the Cadiam spouses, as innocent purchasers for value with a Torrens certificate, incontrovertibly hold that better right.