SC: Property buyers responsible for verifying land titles, registry records | ABS-CBN
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SC: Property buyers responsible for verifying land titles, registry records
Children help out as farmers tend to their crop of cassava in Baras, Rizal on July 4, 2024. Jonathan Cellona, ABS-CBN News
Children help out as farmers tend to their crop of cassava in Baras, Rizal on July 4, 2024. Jonathan Cellona, ABS-CBN NewsMANILA — Buyers of land should verify land titles and other documents and cannot invoke ignorance when these turn out to be fake, according to the Supreme Court.
MANILA — Buyers of land should verify land titles and other documents and cannot invoke ignorance when these turn out to be fake, according to the Supreme Court.
In a decision of the 3rd Division promulgated on November 25, 2024, the court voided two land titles of Orencio and Eloisa Manalese in Angeles City, Pampanga after failing to do due diligence when they bought the properties from Carina Pinpin.
In a decision of the 3rd Division promulgated on November 25, 2024, the court voided two land titles of Orencio and Eloisa Manalese in Angeles City, Pampanga after failing to do due diligence when they bought the properties from Carina Pinpin.
The land titles that Pinpin presented, it turned out, were acquired through fraud by producing duplicate copies of the titles under her name.
The land titles that Pinpin presented, it turned out, were acquired through fraud by producing duplicate copies of the titles under her name.
The true owner, the court noted, is the Ferreras estate, administered by Danilo Ferreras after the original owners Narciso and Ofelia Ferreras died in 1992 and 2005.
The true owner, the court noted, is the Ferreras estate, administered by Danilo Ferreras after the original owners Narciso and Ofelia Ferreras died in 1992 and 2005.
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“Since petitioners did not inquire into the register, and even without such inquiry, they are nonetheless constructively notified of every registration affecting the said subject properties, they cannot feign ignorance of such registrations,” the court said in the decision penned by Alfredo Benjamin Caguioa.
“Since petitioners did not inquire into the register, and even without such inquiry, they are nonetheless constructively notified of every registration affecting the said subject properties, they cannot feign ignorance of such registrations,” the court said in the decision penned by Alfredo Benjamin Caguioa.
The Supreme Court upheld the rulings of the Regional Trial Court and the Court of Appeals which stated that the Manaleses were “buyers in bad faith”.
The Supreme Court upheld the rulings of the Regional Trial Court and the Court of Appeals which stated that the Manaleses were “buyers in bad faith”.
During trial at the CA, it was revealed that Pinpin occupied the properties by mere tolerance of Narciso.
During trial at the CA, it was revealed that Pinpin occupied the properties by mere tolerance of Narciso.
The court noted that the deed of sale presented by Pinpin was executed and notarized in 2009, after the original owners had died.
The court noted that the deed of sale presented by Pinpin was executed and notarized in 2009, after the original owners had died.
Pinpin also claimed to have purchased the properties for P250,000 but sold them in 2010 to the Manaleses for P3.3 million, which the court described as a “massive increase in value.”
Pinpin also claimed to have purchased the properties for P250,000 but sold them in 2010 to the Manaleses for P3.3 million, which the court described as a “massive increase in value.”
“Surely, as prudent persons, they should have inquired from Pinpin why she was able to buy the subject properties at such a low price from Spouses Ferreras,” the court said.
“Surely, as prudent persons, they should have inquired from Pinpin why she was able to buy the subject properties at such a low price from Spouses Ferreras,” the court said.
In a separate concurring opinion however, Associate Justice Henri Jean Paul Inting raised concerns about requiring buyers to investigate as places an undue burden on ordinary buyers and undermines the reliability of certificates of title.
In a separate concurring opinion however, Associate Justice Henri Jean Paul Inting raised concerns about requiring buyers to investigate as places an undue burden on ordinary buyers and undermines the reliability of certificates of title.
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