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  • Tiro v. Philippine Estates Corporation GR No. 170528 Facts

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    Gillian Calpito
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    The petitioners filed a complaint to quiet title against the respondent Philippine Estates Corporation regarding a disputed land claiming their predecessors were the original registered owners. However, the original certificate of title had been cancelled 27 years prior and transferred to other parties, including the respondent. The trial court and appellate court both dismissed the petitioners' case finding their claims of ownership had prescribed and that the respondent was an innocent purchaser in good faith based on the certificate of title. The Supreme Court affirmed finding the respondent was a purchaser in good faith and that certificates of title confirm existing title, but should not be used to perpetrate fraud.

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    Tiro v. Philippine Estates Corporation

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    The petitioners filed a complaint to quiet title against the respondent Philippine Estates Corporation regarding a disputed land claiming their predecessors were the original registered owners. However, the original certificate of title had been cancelled 27 years prior and transferred to other parties, including the respondent. The trial court and appellate court both dismissed the petitioners' case finding their claims of ownership had prescribed and that the respondent was an innocent purchaser in good faith based on the certificate of title. The Supreme Court affirmed finding the respondent was a purchaser in good faith and that certificates of title confirm existing title, but should not be used to perpetrate fraud.

    Copyright:

    © All Rights Reserved
    Flag for inappropriate content
    359 views2 pages

    Tiro v. Philippine Estates Corporation GR No. 170528 Facts

    Uploaded by

    Gillian Calpito
    The petitioners filed a complaint to quiet title against the respondent Philippine Estates Corporation regarding a disputed land claiming their predecessors were the original registered owners. However, the original certificate of title had been cancelled 27 years prior and transferred to other parties, including the respondent. The trial court and appellate court both dismissed the petitioners' case finding their claims of ownership had prescribed and that the respondent was an innocent purchaser in good faith based on the certificate of title. The Supreme Court affirmed finding the respondent was a purchaser in good faith and that certificates of title confirm existing title, but should not be used to perpetrate fraud.

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    © All Rights Reserved
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    Tiro v.

    Philippine Estates Corporation


    GR No. 170528

    FACTS:
    Petitioners filed before the RTC a Complaint for Quieting of Title
    against respondent Philippine Estates Corporation. Petitioners alleged that
    they are the children of the late Julian Tiro and the authorized
    representatives of the Heirs of the late Pedro Tiro. Both decedents were
    purportedly, during their lifetime, the lawful absolute and registered
    owners of the disputed land as evidenced by Original Certificate of Title
    (OCT). Petitioners averred that they and their predecessors-in-interest had
    been in actual possession of the disputed land since time immemorial until
    they were prevented from entering the same by persons claiming to be
    the new owners sometime in 1995. After examining the records found in
    the Office of the Register of Deeds of Lapu-Lapu City, they discovered
    that the OCT had already been cancelled as early as 1969 and was
    issued in favor of Spouses Julio Baba and Olimpia Mesa; and that the
    subject property, after several other transfers, was presently registered in
    the name of respondent under Transfer Certificate of Title. Petitioners
    contend that since Ochea who executed the document Extrajudicial
    Declaration of Heir and Confirmation of Sale, which resulted in the
    cancellation of OCT No. RO-1121 in the name of Julian and
    Pedro Tiro, was not in any way related to Julian and Pedro Tiro; and that
    since Ochea was not an heir of the original registered owners, she had no
    right to cause the transfer of the disputed property and, thus, her transfer
    and all subsequent transfers of said property, including that made to
    respondent, were invalid. The petitioners prayed that all the transactions
    emanating from the Extrajudicial Declaration of Heirs and Confirmation of
    Sale, executed by Maxima Ochea, be declared void, including the
    transfer made in favor of the respondent; that the title which was issued in
    the name of respondent be cancelled; and that the property be restored
    and registered in the name of the petitioners.
    Respondent pointed out that 27 years had elapsed since the
    cancellation of the OCT before petitioners asserted their rights over the
    disputed land. Moreover, petitioners predecessors-in-interest Julian and
    Pedro Tiro did not question the cancellation of their title to the property
    during their lifetimes. Hence, respondent argued that petitioners action for
    quieting of title was barred by laches and prescription.
    RTC dismissed the petitioners’ complaint. It ruled that petitioners
    claims of filiation to Julian and Pedro Tiro were not supported by
    documents. And even assuming that petitioners were heirs of the late
    Julian and Pedro Tiro, and Maxima Ochea was in no way related to them,
    petitioners claims had already prescribed, considering that the Complaint
    was filed more than ten years since the registration of the disputed
    property in the name of the Spouses Baba in 1969. Lastly, the RTC ruled
    that respondent was an innocent purchaser for value who relied on the
    correctness of the certificate of title in the name of the vendor.
    The Court of Appeals likewise denied their appeal.

    ISSUE:
    Whether or not the Court of Appeals erred in affirming the decision
    of the RTC

    HELD:
    No. The respondent is a purchaser in good faith. A person is
    considered in law as an innocent purchaser for value when he buys the
    property of another, without notice that some other person has a right or
    an interest in such property, and pays a full price for the same at the time
    of such purchase, or before he has notice of the claims or interest of some
    other person in the property. A person dealing with registered land may
    safely rely on the correctness of the certificate of title of the
    vendor/transferor. The property in question had already been the subject
    of five succeeding transfers to persons who were not accused of having
    purchased the same in bad faith. Petitioners attempt, therefore, to have
    respondents certificate of title to the disputed property annulled, must fail.
    Certificates of title merely confirm or record title already existing
    and vested. The indefeasibility of the torrens title should not be used as a
    means to perpetrate fraud against the rightful owner of real
    property. Good faith must concur with registration because, otherwise,
    registration would be an exercise in futility.
    Petition denied.

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