When is one constructively notified of adverse claims against his title?
(First of two parts)
Generally, every person dealing with registered land may safely rely on the certificate of title, such that he need not go beyond it to determine the condition of the property.
This rule, however, does not absolutely apply, as recently held by the Supreme Court in Republic of the Philippines v. Espejo, et al.
This case involved three parcels of land originally registered under a certain Faustina Rubis. She executed a deed of donation of a certain portion of the disputed property in favor of the Roxas Municipal High School (RMHS). Nevertheless, Rubis’ daughter, Felisa Vidal, successfully acquired the entire disputed property, selling a portion thereof to Faustino Llanes, one of the respondents in this case.
Petitioner Republic of the Philippines—represented by the Department of Education-Regional II—alleged that to make it appear that Felisa had ratified Rubis’ donation to RMHS, she executed the corresponding deed of donation. Since the portion of the property as described in the deed, differed from what Rubis had actually donated, the Municipality of Roxas filed an adverse claim over the donated property. It also caused a Notice of Lis Pendens to be recorded on the title when it initiated special proceedings before the Regional Trial Court (RTC).
In its Decision, the RTC held that the Municipality and Felisa entered into a compromise agreement, where the latter would surrender the title to the donated portion upon the former’s payment. This is to allow the Municipality to register the deed of donation and secure the title in its name.
This compromise agreement was recorded on the title of the disputed property. Consequently, Felisa and Faustino executed deeds of conveyance and waiver in favor of RMHS, reconveying the donated land. These deeds were also recorded on the title. Thereafter, this title was cancelled and a new one issued in the name of RMHS.
According to the Republic, the new title failed to further reflect agreement that Rubis only donated a portion of the disputed property, while the remaining portion would be used as a road lot. Supposedly taking advantage of the non-segregation of the donated property from the road lot, Faustino, Felisa, and co-respondent Constance Sales, who represented the Department of Education, Culture, and Sports–Roxas National High School (DEPED Roxas NHS), which eventually acquired the title from RMHS, executed joint affidavits of conformity, stating their agreement to cause the subdivision of lots under a certain subdivision plan.
Constance reconveyed certain portions of the property to Felisa and Faustino, which transactions had been annotated on the title. Thereafter, Faustino sold his portion to co-respondent Carolina Espejo.
Meanwhile, Felisa died, leaving her three children, respondents Roger, Alma, and Helen Umipig (collectively, “Umipigs”) to inherit and extrajudicially settle her portion in favor of Roger, who subsequently sold it to co-respondent Gregorio Espejo. The corresponding title was issued in favor of Gregorio.
While DEPED Roxas NHS continued to own the remaining portion of the property as erroneously referred to in the new title, the Republic alleged that Constance, then in her capacity as principal of DEPED Roxas NHS, executed a deed of reconveyance over this portion in favor of the Umipigs. Subsequently, the Umipigs sold this portion to respondents Grelinda Espejos and Carolina (collectively, the “Espejos”).
DEPED Roxas NHS filed the instant complaint against respondents before the RTC, mainly arguing that: (a) Gregorio could not have acquired any valid title over the portion formerly claimed by Roger since he knew that it comprised the donated property to DEPED Roxas NHS, as well as the road lot; (b) Constance connived with the Umipigs to make it appear in the subdivision plan that DEPED Roxas NHS’s portion was composed of the two smaller lots reconveyed by the Umipigs; and (c) Constance was not authorized to dispose of DEPED Roxas NHS’s property.
Meanwhile, the Espejos claimed that they had validly acquired ownership over the entire disputed land in good faith and for value since the titles presented to them did not contain any adverse claims or encumbrances.
(To be continued)
