When is one constructively notified of adverse claims against his title?
(Conclusion)
As previously discussed, Republic of the Philippines v. Espejo, et al. concerned three parcels of land donated to the Roxas Municipal High School (RMHS), now replaced by the Department of Education, Culture, and Sports-Roxas National High School (DepEd Roxas NHS), which represented petitioner Republic of the Philippines.
In filing before the Regional Trial Court (RTC) a complaint for cancellation of titles, reconveyance of property, and damages, DepEd Roxas NHS argued that, among others, respondent Gregorio Espejo could not have acquired any valid title over the disputed portion of the land since he knew that it should have comprised the donated property and the road lot, as supposedly agreed upon with its donor, Faustina Rubis.
Meanwhile, respondents Grelinda Espejos and Carolina (collectively, the “Espejos”), who by then were the registered owners of all parcels of land, claimed that they had validly acquired ownership over them in good faith and for value since the titles presented to them did not contain any adverse claims or encumbrances.
Nevertheless, before buying the land, they made inquiries from the Register of Deeds and certain officials, conducted an ocular inspection, and gave consideration to the occupants, who supposedly recognized that co-respondents and former owners Roger, Alma, and Helen Umipig (collectively, “Umipigs”) owned the same, and not DepEd Roxas NHS.
The RTC ruled in favor of the Espejos, declaring them to be buyers in good faith since the Umipigs were the registered owners of the disputed land. Moreover, the respective titles did not have any affidavit of adverse claim.
Upon appeal, the Court of Appeals affirmed the RTC’s findings and found that the Espejos had employed sufficient measures before buying the disputed land. To be sure, it sufficed for the Espejos to have looked into the titles of their predecessors, the Umipigs and co-respondent Faustino Llanes, which did not contain the annotations on the donation between RMHS and Rubis. If the Umipigs and Llanes fraudulently sold the disputed land, the Espejos were not privy to the same and thus, are purchasers in good faith and for value entitled to own the same.
These incidents constrained DepEd Roxas NHS to file the instant petition before the Supreme Court, which reversed and set aside the lower courts’ findings and declared void respondents’ titles to the disputed land.
In ruling in this manner, the Supreme Court held that there had been a misapprehension of facts, such that the Espejos were not innocent purchasers for value. While Espejos did not personally encounter the title registered under RMHS’s name with the necessary annotations, they were charged with constructive notice of these annotations, as well as all encumbrances, affecting their title.
In this regard, the Property Registration Decree states that every conveyance, instrument, or entry affecting registered land shall, if registered, filed, or otherwise entered in the Register of Deeds, operate as constructive notice to all persons from such time of registering, filing, or entering.
The rule on constructive notice presumes that its purchaser has examined every instrument of record affecting the title. This rule equally applies upon the registration of every conveyance, mortgage, lease, lien, attachment, order, judgment, instrument, or entry affecting the registered land, and cannot be refuted by proof of innocence or good faith.
In this case, an irrefutable presumption of constructive notice exists on the part of the Espejos, despite them not having personally encountered RMHS’s title, which was recorded before the Registry of Deeds. This also charges them with being aware of the lack of authority of co-respondent Constance Sales, who represented DepEd Roxas NHS, to execute the deeds of conveyances in favor of the Umipigs and Llanes.
Since these deeds were executed without DepEd Roxas NHS’s authority, they would be unenforceable and not binding on it, pursuant to the Civil Code.
Meanwhile, even if the Espejos could be considered as innocent purchasers for value, DepEd Roxas NHS has a superior right over the disputed land.
Thus, as with DepEd Roxas NHS, the registered owner of land who was not negligent in keeping its duplicate certificates of title or with any other act that could have brought about the issuance of another title relied upon by the purchaser for value would have a better right over the latter.
