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Casimiro Development Corp. v.

Mateo

G.R. No. 175485, 24 July 2011

FACTS:

1) Registered parcel of land originally owned by Isaias Lara, respondents’ maternal grandfather, which was
passed on to his children.

2) The co-heirs effected the transfer of the full and exclusive ownership to Felicidad Lara-Mateo.

3) Deed of sale was executed in favor of Laura, one of Felicidad’s children, who applied for land registration;
OCT was thereafter issued.

4) Property used as collateral to secure a succession of loans, a TCT of which was eventually issued in the
name of China Bank.

5) Casimiro Development Corp. thereafter purchased the property from CB; Felicidad died intestate.

6) CDC brought action for unlawful detainer in the MeTC against the sons of Felicidad; the latter claimed
MeTC did not have jurisdiction; the land was classified as agricultural; has been in continuous possession
of the land.

7) MeTC ruled in favor of CDC, RTC against, CA and SC in favor CDC.

8) Respondent brought action for quieting of title, RTC favored CDC, CA against (not a buyer in good faith).

ISSUE: Is the concerned Certificate of Title in the name of Laura indefeasible and imprescriptible?

RULING: Yes. The property has already been placed under the Torrens system of land registration before
CDC became the registered owner by purchase from China Bank; OCT has already been issued to attest
to the fact that the person named in the certificate is the owner of the property therein described, subject to
liens and encumbrances as thereon noted or what the law warrants or reserves. Neither the respondent
nor his siblings opposed the transactions causing various transfers, and even acknowledged the registration
of the land under the name of Laura.

CDC was an innocent purchaser for value. Considering that China Bank’s TCT was clean title, that is, it
was free from any lien or encumbrance, CDC had the right to rely, when it purchased the property, solely
upon the face of the certificate of title in the name of China Bank.

NB:

If a person purchases a piece of land on the assurance that the seller’s title thereto is valid, he should not
run the risk of being told later that his acquisition was ineffectual after all, which will not only be unfair to
him as the purchaser, but will also erode public confidence in the system and will force land transactions to
be attended by complicated and not necessarily conclusive investigations and proof of ownership.

The Torrens certificate of title is merely an evidence of ownership or title in the particular property described
therein. The issuance of the certificate of title to a particular person does not preclude the possibility that
persons not named in the certificate may be co-owners of the real property therein described with the
person named therein, or that the registered owner may be holding the property in trust for another person.

Registration of land under the Torrens System, aside from perfecting the title and rendering it indefeasible
after the lapse of the period allowed by law, also renders the title immune from collateral attack.

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