Professional Documents
Culture Documents
CA
198 SCRA 434 (1991)
FACTS: Subject lot was originally owned by spouses Juan and Rafaela. When Juan
died ownership was transferred to Rafaela and her two sons: Raymundo and Cicero.
The lot was then sold to Rafaela who acquired title thereto. She first sold a portion
of the lot in 1967, then sold the other portion later. Ownership was eventually sold
to Pino who registered the sale in 1970. In 1980 Cicero died and his heirs instituted
suit for nullity and reconveyance against Pino.
RULING: Yes. Where the certificate of title is in the hands of the vendor when the
land is sold, the vendee for value has the right to rely on what appears on the
certificate of title. In the absence of anything to excite or arouse suspicion, the
vendee is under no obligation to look beyond the certificate and investigate the title
of the vendor.
The main purpose of the Torrens system is to avoid possible conflicts of title to real
estate and to facilitate transactions relative thereto by giving the public the right to
rely upon the face of the TCT and dispense with the need for inquiring further
except when the party concerned has actual knowledge of facts and circumstances
that should impel a reasonably cautious man to make such further inquiry.
The action had already prescribed because it was filed 15 years after the sale and
issuance of TCT in 1967. The remedy for the petitioner is to bring action for
damages against those who caused the fraud.