Navarro v. Go
REITERATIONFacts
The Antecedents: By Deed of Sale dated May 23, 1937, Emilia Samson conveyed a parcel of land to Josefa Parras, mother of respondent Perla Rico Go. In 1971, Free Patent No. 51563 was issued to the Heirs of Lorenzo Samson, brother of Emilia, covering the same land. Josefa allowed Rufino Palma, nephew of petitioner Cesaria, to stay on the land after her purchase in 1937. Respondent inherited the land from Josefa in 1984 and allowed Palma to remain until 1989. Palma executed two "Paknaan" documents recognizing respondent's ownership. Upon Palma's vacating, respondent fenced the property and posted a "Private Property, No Trespass" sign. In 1990, the Samson heirs transferred their rights to petitioners Spouses Braulio Navarro and Cesaria Sindao via a Deed of Extra-Judicial Partition with Sale. In 2001, Transfer Certificate of Title No. 254853 was issued in petitioners' names. Petitioner Braulio destroyed the fences and cut trees on the land. Procedural History: Respondent filed a complaint for annulment of documents and damages against petitioners. Petitioners invoked good faith, citing the absence of encumbrances on the title at the Register of Deeds. The RTC ruled in favor of respondent, declaring the free patent title a nullity and upholding respondent's possession. The RTC noted petitioners' proximity to the land and the visible improvements, disregarding their claim of good faith. The Court of Appeals affirmed the RTC's decision with modification, ordering petitioners to reconvey the title to respondent instead of nullifying the titles. Petitioners' motion for reconsideration was denied. The Petition: Petitioners seek review of the Court of Appeals decision, maintaining their good faith in purchasing the land and relying on the principle that one dealing with registered land need only rely on the certificate of title.
Issue(s)
Whether petitioners are purchasers in good faith and for value. Whether the Court of Appeals erred in ordering reconveyance despite the absence of such prayer in the complaint.
Ruling
The petition is denied. The Court of Appeals Decision of December 12, 2008 is affirmed.
Ratio Decidendi
On Whether petitioners are purchasers in good faith and for value: The Court held that while a person dealing with registered land may generally rely on the certificate of title, this principle cannot be used to perpetuate fraud. Petitioners' claim of good faith was negated by several factors. Firstly, Rufino Palma, who occupied the land and was a relative of petitioner Cesaria, had acknowledged respondent's ownership through documentary evidence ("Paknaan"). Palma's testimony that he sought permission from the Samson heirs, not from respondent or her mother, was thus discredited. Secondly, petitioners resided in close proximity to the land, which was fenced and had fruit-bearing trees, indicating visible possession by someone other than the vendor. This proximity and the visible improvements should have put petitioners on notice, requiring them to go beyond the certificate of title. The Court reiterated that where the land is in possession of a person other than the vendor, prudence dictates that the vendee conduct further investigation, and the absence of such investigation negates good faith. The factual findings of the RTC, affirmed by the CA, that petitioners had notice of respondent's possession were not disturbed as no exceptions under Rule 45 were present. On Whether the Court of Appeals erred in ordering reconveyance despite the absence of such prayer in the complaint: The Court affirmed the CA's modification, citing the principle that courts can grant legal remedies proper to a proven cause of action even if not expressly prayed for. The CA correctly stated that an action for reconveyance falls within the ambit of a general prayer to "relinquish all claims to the property to the plaintiff." Therefore, the CA did not err in ordering reconveyance as a remedy to protect respondent's proven ownership and possession against petitioners' fraudulent acquisition of title.
Main Doctrine
The indefeasibility of a Torrens title cannot be used to perpetuate fraud against the rightful owner. A vendee who purchases a property in possession of another must go beyond the certificate of title to ascertain the condition of the property; failure to do so negates good faith.