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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
In Sps. Manalese v. Estate of Sps. Ferreras, the Supreme Court ruled that land buyers must verify ownership by checking the certificate of title and reviewing the records in the Registry of Deeds to avoid fraudulent transactions.
In this case, the Supreme Court affirmed the rulings of the lower courts declaring the sale and subsequent transfers of two parcels of land in Sta. Teresita, Angeles City, null and void. The properties were originally owned by Spouses Narciso and Ofelia Ferreras, who died in 2005 and 1992, respectively. Despite their passing, a Deed of Absolute Sale dated 2009 was allegedly executed in favor of Carina Pinpin, who then sold the properties to Spouses Orencio and Eloisa Manalese and their son, Aries, in 2010. The petitioners argued they were innocent purchasers for value, citing clean titles and lack of visible claims. Nonetheless, the Court found that they failed to exercise the required level of diligence, especially in light of the obvious impossibility of a valid sale executed by deceased persons. The Court held that the petitioners were not buyers in good faith and upheld the annulment of their titles.
Now, given this chain of transactions originating from a sale supposedly executed by registered owners long after their death, can the petitioners still be considered buyers in good faith and for value?
The Supreme Court denied the petition and affirmed the findings of the Regional Trial Court and the Court of Appeals, holding that the petitioners were NOT buyers in good faith and for value. The Supreme Court emphasized that the 2009 Deed of Absolute Sale executed by Spouses Narciso and Ofelia Ferreras in favor of Carina Pinpin was void ab initio, as both spouses were already deceased prior to the alleged sale. As the Court categorically stated, “When the deed of sale in favor of Pinpin was purportedly executed and notarized on May 11, 2009, it is perfectly obvious that the signatures of vendors… were forged.”
As the original sale was void, the titles issued to Pinpin and subsequently to the Manaleses produced no legal effect. The Court reiterated that a forged deed “produces no civil effect and does not create, modify or extinguish a juridical relation.” Thus, Pinpin acquired no rights, and the estate of the Ferreras spouses retained ownership.
The petitioners’ claim of good faith was also rejected. The Court highlighted their failure to conduct even basic due diligence, stating that the Manaleses did not examine the property’s history or inquire further into Pinpin’s right to sell. The Court found it “confounding” that Orencio Manalese failed to question why Pinpin, who allegedly acquired the properties for only PHP 250,000, was demanding PHP 3.3 million from them.
Significantly, the Court emphasized that there was a laundering of the titles. The annotations that appeared in the original titles, such as affidavits of loss and judicial orders, were suspiciously omitted in Pinpin’s titles, giving them a false appearance of being “clean.” This then further cast doubt on the validity of the transfers.
In holding that petitioners were not innocent purchasers for value, the Court echoed its earlier ruling in Garcia v. CA, emphasizing that persons dealing with questionable titles must be “extra-careful,” particularly where the certificates on their face indicate irregularities in the chain of ownership.
Source:
- Spouses Orencio S. Manalese and Eloisa B. Manalese, and Aries B. Manalese Vs. The Estate of the Late Spouses Narciso and Ofelia Ferreras, represented by its Special Administrator, Danilo S. Ferreras (G.R. No. 254046 | November 25, 2024)
- SC: Land Buyers Must Check Both Title and Registry of Deeds Records
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Alburo Alburo and Associates Law Offices specializes in business law and labor law consulting. For inquiries regarding legal services, you may reach us at info@alburolaw.com, or dial us at (02)7745-4391/ 0917-5772207/ 09778050020.
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