Cruz vs Secretary of DENR Natural Resources and On February 25, 1968, Michael filed a miscellaneous sales

Environmental Law application covering the reclaimed foreshore land. On the

IPRA; Regalian Doctrine other hand, petitioner Baguio applied to the Bureau of Lands
GR. No. 135385, Dec. 6, 2000 for a free patent over the same land stating that the land was
agricultural and he has been in actual and continuous
FACTS: Petitioners Isagani Cruz and Cesar Europa filed a suit possession of the same. A free patent was issued in Baguio’s
for prohibition and mandamus as citizens and taxpayers, favor by the Register of Deeds of Cebu. The petitioner now
assailing the constitutionality of certain provisions of Republic demands rental payment from Michael for using the land
Act No. 8371, otherwise known as the Indigenous People’s occupied by Michael Slipways, Inc. and filed an opposition to
Rights Act of 1997 (IPRA) and its implementing rules and Michael’s miscellaneous sales application on the said land. In
regulations (IRR). The petitioners assail certain provisions of turn, Michael filed a protest on the issuance of the free
the IPRA and its IRR on the ground that these amount to an patent to Baguio by the Bureau of Lands since he is the actual
unlawful deprivation of the State’s ownership over lands of possessor of the land since 1963 and introduced substantial
the public domain as well as minerals and other natural improvement thereon.
resources therein, in violation of the regalian doctrine
embodied in section 2, Article XII of the Constitution. Upon recommendation of the Land Management Bureau of
the Department of Environment and Natural Resources, the
ISSUE: Do the provisions of IPRA contravene the Constitution? government filed a petition for the cancellation of the patent
and reversion of land to the public domain. Ricardo Michael
HELD: No, the provisions of IPRA do not contravene the was allowed to intervene as heir and successor-in-interest of
Constitution. Examining the IPRA, there is nothing in the law William Michael. The trial court cancelled the free patent of
that grants to the ICCs/IPs ownership over the natural Baguio and ordered the reversion of the land to public
resources within their ancestral domain. Ownership over the domain. It ruled that the false statement that Baguio made in
natural resources in the his application for free patent had the effects of ipso facto
ancestral domains remains with the State and the rights canceling the free patent granted to him. On appeal,
granted by the IPRA to the ICCs/IPs over the natural resources petitioner assails the court decision of cancelling his patent
in their ancestral domains merely gives them, as owners and since the action has already prescribed and that it erred in
occupants of the land on which the resources are found, the ruling that he acted in bad faith and procured the registration
right to the small scale utilization of these resources, and at of his free patent through fraud and misrepresentation.
the same time, a priority in their large scale development and
exploitation. Issue:
Whether or not the free patent of the petitioner may be
Additionally, ancestral lands and ancestral domains are not cancelled?
part of the lands of the public domain. They are private lands
and belong to the ICCs/IPs by native title, which is a concept Ruling:
of private land title that existed irrespective of any royal grant The Supreme Court that while a Torrens Title becomes
from the State. indefeasible within 1 year after its registration the State may
However, the right of ownership and possession by the still bring action for reversion of a parcel of land to the public
ICCs/IPs of their ancestral domains is a limited form of domain covered by a Torrens title obtained through fraud
ownership and does not include the right to alienate the because such action is not barred by prescription as provided
same. by Commonwealth 141. Public policy demands that one who
obtains title from a public land through fraud should not be
allowed to benefit from it. The declaration of the petitioner in
Francisco Baguio v RP, GR No. 119682, January 21, 1999 (301 his application for patent
SCRA 450)
RODRIGUEZ vs. LIM
Facts: GR NO. 135817 / NOVEMBER 30, 2006
William Michael filed with the Bureau of Lands an application
for foreshore lease of a public land. The application was FACTS:
recommended for approval by the land investigator who also Lim Jr., filed a complaint for cancellation of
recommended that the applicant be granted a provisional certificate of title and injunction against Spouses Rodriguez.
permit to occupy the land for one year. By virtue of the In his complaint, the former alleged that his mother, Dominga
permit, Michael made reclamation of the land introducing Goyma was the owner of two parcels of land, registered
improvements therein. Upon the expiration of the permit the under TCT No. T-2857. Dominga Goyma died on July 19, 1971
Highways District Engineer recommended to the Director of and was survived by him, Lim Jr., a spurious son
Lands that the land be leased to Michael. On the other hand, acknowledged and recognized by her. Spouses Rodriguez,
the land investigator recommended granting Michael the despite their knowledge that Lim Jr is the owner of the
authority to survey the foreshore land in view of the property, allegedly and fraudulently made it appear that they
completion of the reclamation made by him on the premises.
had purchased the subject lots from persons who were not innocent purchaser for value is one who buys the property of
owners thereof. Pursuant to an affidavit of loss and a another without notice that some person has a right or
reconstitution proceeding, TCT No. T-2857 was cancelled and interest in it, and who pays a full an fair price at the time of
TCT No. T-128605 was issued in the name of Frisco Gudani, purchase or before receiving any notice of another person’s
estranged husband of Dominga. TCT No. T-128605 was claim. In the case at bar, respondents cannot be considered
cancelled and TCT No. T-128606 was issued in the name of an innocent purchaser for value. For one, Rufloe filed a notice
Eduardo Victa. TCT No. 128606 was cancelled and TCT No. T- of adverse claim and have the same annotated in the title.
128607 was issued in the name of Spouses Rodriguez. These Despite such notice, the Burgos siblings still purchased the
three (3) TCTs are issued on the same date February 10, 1975. property in question.
Further, Delos Reyes was not in possession of the
Issue: subject property when she sold the same to the Burgos
WON TCT No. T-128607 be cancelled considering the fact that siblings, but the Rufloes. Since it was the Rufloes who
it is protected by the indefeasibility rule. continued to have actual possession of the property,
Leonarda should have investigated the nature of their
Ruling: possession. Moreover, the defense of indefeasibility of a
Yes. It has been consistently ruled that “when the owner’s Torrens title does not extend to a transferee who takes it with
duplicate certificate of title has not been lost, but is in fact, notice of a flaw in the title of his transferor.
had been in the possession of another person, then the
reconstituted certificate is void, because the court that
rendered such a decision has no jurisdiction. Applying the said Peralta v. Abalon, GR 183448, June 30, 2014
principle, it is apparent that TCT No. 128605 was void.
Moreover, petitioner cannot raise the defense of Facts:
indefeasibility because the said principle does not apply Lot 1679 consisting of 8,571 square meters was originally
where fraud attended the issuance of a certificate of title. The covered by OCT No. (O) 16 and registered in the name of
Torrens title does not furnish a shield for fraud. Bernardina Abalon (Abalon). It appears that a Deed of
Absolute Sale was executed over the subject property in favor
Rufloe v. Burgos, GR 143573, Jan. 30, 2009 of Rellama on June 10, 1975. By virtue of such conveyance,
OCT No. (O) 16 was cancelled and in lieu thereof, TCT No.
FACTS: 42108 was issued in the name of Rellama. TCT No. 42108 was
Sometime in 1978, respondent Elvira Santos forged the subdivided into three (3) portions and was sold in the
signatures of Adoracion and Angel Rufloe in a Deed of Sale following manner: Lot 1679-A was sold to Spouses Peralta, for
dated September 8, 1978 to make it appear that the disputed which reason TCT No. 42254 was issued their names; Lot
property was sold to her by the Spouses Rufloe. On the basis 1679-B was first sold to Lotivio who thereafter transferred his
of the said deed of sale, Delos Reyes succeeded in obtaining a ownership thereto to Andals and TCT No. 42482 was issued in
title in her name, TCT No. S-74933. In November 1979, the their names; and Lot 1679-C also acquired by the Andals as
Rufloes filed a complaint for damages against Delos Reyes evidenced by the issuane of TCT No. 42821. Claiming that the
with the RTC of Pasay City alleging that the Deeds of Sale was Deed of Absolute Sale executed by Abalon in favor of Rellama
falsified as the signatures appearing thereon were forged was a forged document, and claiming further that they
because Angel Rufloe died in 1974 which was four years acquired the subject property by succession, being the
before the alleged sale in favor of Delos Reyes. They also filed nephew and niece of Abalon who died without issue.
a notice of adverse claim on November 5, 1979.
ISSUE:
On December 4, 1984, during the pendency of the case, Delos
Reyes sold the same property to the Burgos siblings. A new WON Spouses Peralta and the Andals are innocent
title, TCT No. 135860. was then issued in their names. On purchaser for value.
December 12, 1985, Burgos sibilings sold the said property to
their aunt, Leonarda Burgos. However the sale in favor of Ruling:
Leonarda was not registered. Thus, no title was issued under Andals are innocent purchaser for value due to the
her name. The said property remained in the name of Burgos fact that there is no evidence that the chain of registered
siblings. titles was broken in the case of the Andals. Neither were they
proven to have knowledge of anything that would make them
ISSUE: suspicious of the nature of Rellama’s ownership over the
WON respondents were innocent purchasers in good faith subject parcel of land. Consequently, the validity of their title
and for value despite the forged deed of sale of their to the parcel of the land bought from Rellama must be
transferor Delos Reyes. upheld.
As for Spouses Peralta, the Supreme Court sustain
Ruling: the ruling of the CA that they were buyers in bad faith. The
No. A forged deed can legally be the root of a valid appellate court made a factual finding that in purchasing the
title when an innocent purchaser for value intervenes. An
subject property, they merely relied on the photocopy of the title was issued pursuant thereto. On the other hand,
title provided by Rellama. The CA concluded that a mere Francisco Bombast likewise filed a petition for reconstitution
photocopy of the title should have made Spouses Peralta that with CFI Rizal covering Lot No. 918 and the same was also
there was some flaw in the title of Rellama, because he was granted. Bombast sold Lot No. 918 to Deo and the latter sold
not in possession of the original copy. This factual finding was the lot to A & A Torrijos Engineering Corporation.
supported by evidence
On May 25 and 26, 1970, the State filed two petitions for the
Dy vs. Aldea, GR No. 219500, August 9, 2017, citing cancellation and annulment of the reconstituted titles and
Locsin vs. Hizon, GR No. 204369, September 17, 2014 titles issued subsequent thereto.

FACTS: Issue:
Dy is the owner of Lot 5158 with an area of 6,738 WON the petition will prosper.
square meters, and covered by TCT No. T-24849. In June
2005, Mamerto agreed to sell the subject land to his brothers Ruling:
Nelson Dy ad Sancho Dy, Jr. After asking copies of the tax YES. The existence of the two titles of the
declarations of the subject land from the Municipal Assessor’s Government for Lot Nos. 915 and 918 ipso facto nullified the
Office, Nelson found out that the subject land had gone reconstitution proceedings and signified that the evidence in
through a series of anomalous transactions. The owner’s the said proceedings as to the alleged ownership of Laborada
duplicate copy of the same TCT was declared lost. As a result, and Bombast cannot be given any credence. The two
a new owner’s duplicate copy of the same TCT was issued and proceedings were sham and deceitful and were filed in bad
the subject land was subsequently mortgaged. Later, it was faith. Such humbuggery or imposture cannot be
found out that the said lot was sold to Lourdes by an countenanced and cannot be the source of legitimate rights
impostor Mamerto. and benefits.

Issue: Sandoval v. CA, GR No. 106657, Aug. 1, 1996, 260 SCRA 283
WON Lourdes is an innocent purchaser for value.
Facts:
Ruling: The property subject of the controversy is a parcel of
No. Lourdes did not conduct a thorough land on which a five-door apartment building stands, covered
investigation and she merely instructed her uncle to check by TCT No. 196518 in the name of Lorenzo Tan Jr., married to
with the Register of Deeds whether the subject land is free Carolina Mangampo, located at QC. Lorenzo Tan Jr., was
from any encumbrance. Further, Lourdes met the seller only notified of the need to present his owner’s copy of the TCT in
during the signing of the two deeds of sale. Yet, she did not connection with an adverse claim. He explained that he was
call into question why the seller refused to see her during the still looking for his copy of the TCT. Later, he discovered that
negotiation. For sure, an ordinary prudent buyer of real the adverse claim of Godofredo Valmeo had been annotated
property who would be relinquishing a significant amount of on his title in the Registry of Deeds. An impostor Lorenzo Tan
money would want to meet the seller of the property and Jr., had mortgaged the property to Valmeo to secure a
would exhaust all means to ensure that the seller is the real P70,000 obligation.
owner thereof.
Tan filed a complaint for cancellation of the
Republic v. CA, GR L-46626-27, Dec. 27, 1979 annotation of mortgage and damages against Bienvenido
Almeda and Godofredo Valmeo. Upon further investigation,
Facts: he discovered that someone purporting to be him, sold the
These two cases are about the cancellation and property to Bienvenido Almeda in a Deed of Sale of
annulment of the reconstituted Torrens titles whose originals Registered Land with Pacto de Retro. Subsequently, TCT No.
are existing and whose reconstitution was uncalled for. Lot 196518 was cancelled and a new one, TCT No. 326781 was
Nos. 915 and 918 of the Tala Estate are registered in the issued in the name of Bienvenido Almeda. Bienvenido sold
name of the Commonwealth of the Philippines as shown in the property to Juan Sandoval and TCT No. 329487 was issued
TCT Nos. 34594 and 34596 of the Registry of Deeds of Rizal unto his favour.
both dated April 30, 1938. The originals of these titles are on
file in the Registry of Deeds and were not destroyed during Issue:
the war. WON Sandoval is a purchaser in good faith or an innocent
purchaser for value.
The reconstitution proceeding started when
Fructuosa Laborada, a widow, filed with CFI Rizal a petition Ruling:
for reconstitution of title covering Lot No. 915. She alleged NO. The Supreme Court held that a fraudulent or
that she was the owner of the lot and that the title covering forged document of sale may give rise to a valid title if the
it, the number of it she could not specify was “N.A.” or not certificate of title has already been transferred to from the
available. The petition was granted and a new certificate of name of the true owner to the same indicated by the forger
and while it remained as such, the land was subsequently sold Sometime on March 22, 1966, petitioner applied for land
to an innocent purchaser. registration of a 1,147 square meters residential lot. Her
application substantially stated that petitioner is the owner in
It is settled that one who deals with property fee simple of the land and improvements thereon as her
registered under the Torrens system need not go beyond the acquisition by inheritance from her father, the late Pascual
same, but only has to rely on the title He is charged with Monge who died on June 9, 1950, and that the same parcel of
notice only of such burdens and claims as are annotated on land is her share in a partial partition of estate she and her
the title. The aforesaid principle admits of an unchallenged brothers and sisters executed on May 22, 1964; that she and
exception: that a person dealing with registered land has a her predecessors in interest have been in continuous, public,
right to rely on the Torrens certificate of title and to dispense actual and adverse possession of the land applied for since
with the need of inquiring further except when the party has time immemorial until the present.
actual knowledge of facts and circumstances that would
impel a reasonably cautious man to make such inquiry, or After due publication of the Notice of Initial Hearing of the
when the purchaser has knowledge of a defect or the lack of petition in the Official Gazette, only the Highway District
title in his vendor or of sufficient facts to induce a reasonably Engineer of Leyte as public oppositors, and Concordia
prudent man to inquire into the status of the title of the Lanuncia, Flaviano L. Marchadesch, Jr., and herein private
property in litigation. The presence of anything which excites respondent Maximina L. Moron as private oppositors
or arouses suspicion should then prompt the vendee to look appeared for the initial hearing before the trial court.
beyond the certificate and investigate the title of the vendor A judgment was hereby rendered ordering the registration of
appearing on the face of said certificate. One who falls within title in the name of the petitioner with ¾ share and of
the exception can neither be denominated an innocent respondent Moron, for 1/12 share, among others.
purchaser for value nor a purchaser in good faith; and hence,
does not merit the protection of the law. The trial court gave significant weight to the carbon copy of a
power of attorney executed and signed by the late Pascual
A purchaser in good faith is one who buys the Monge on February 11, 1945 in favor of Maximina L. Moron,
property of another, without notice that some other person wherein he stated that Maximina is his daughter and
has a right to, or interest in, such property and pays a full and appointed her as his Attorney-in-Fact to transact with the
fair price for the same, at the time of such purchase, or United States Armed Forces in the Philippines in his behalf for
before he has notice of the claim or interest of some other the collection of rentals and other war damage claims due
persons in the property. A purchaser cannot close his eyes to and payable to him. The court ruled that the power of
facts which should put a reasonable man on guard and still attorneywas an authentic writing wherein Maximina Lanuncia
claim he acted in good faith. was voluntarily recognized as the daughter of Pascual Monge.

In the case at bar, even if Sandoval acquire the Petitioner assailed the Court’s decision in her motion for
property after it was advertised for sale in the Bulletin issue reconsideration. Acting upon the
of March 3, 1985, the court strongly doubts his claim of good aforesaid motion for reconsideration, the Court modified its
faith. In the first place, it was testified by the Registry of decision giving 13/14 share to Moscoso and 1/14 share to
Deeds of QC that there are two copies of TCT No. 196518 in Moron. Not satisfied with the amended judgment, petitioner
the Registry of Deeds, only one could be genuine. Secondly, elevated the case to the Court of Appeals which affirmed the
there was an error in the address of Almeda which is not judgment of the lower court. Hence, the
likely that Sandoval could have mistaken about the street instant petition before Supreme Court.
where his vendor allegedly resided. Thirdly, equivocations
were obviously committed by Sandoval in his testimony, Issue
which taken together, tender to render improbable The lower court erred in making judicial pronouncements
Sandoval’s claim of good faith. Fourth, Sandoval could have that Maximina Lanuncia Moron as the
unavoidably noticed the several but varying addresses of acknowledged natural child of Pascual Monge conferring
Almeda which were suspicious, to say the least. Lastly, upon her legal right to inherit from the
Certification appearing on the deed of sale that the property whole estate of the late Pascual Monge
was not tenanted was plainly untrue. The making of
untruthful certification, the contrary to which was something Ruling
well known by Almeda and Sandoval, betrayed an awareness Petitioner’s contention that the Court of First Instance, acting
on their part of flaws in the transaction. as a land registration court, has no
jurisdiction to pass upon the issue whether the oppositor is
ANDREA M. MOSCOSO, petitioner, vs. COURT OF APPEALS the acknowledged natural child of
and MAXIMINA L.MORON, respondents. Pascual Monge, is untenable.
No. L-46439. April 24, 1984 The proceedings for the registration of title to land under the
Torrens system.
Facts
NOTES:
Concept of Jura Regalia Exception
Under the Regalian doctrine, all lands of whatever A person dealing with registered land has a right to rely on
classification and other natural resources not otherwise the Torrens certificate of title and to dispense with the need
appearing to be clearly within private ownership belong to of inquiring further except when the party has actual
the State. The State is the source of any asserted right to knowledge of facts and circumstances that would impel a
ownership of land and charged with the conservation of such reasonably cautious man to make such inquiry or when the
patrimony. Accordingly, public lands not shown to have been purchaser has knowledge of a defect or the lack of title in his
reclassified or released as alienable agricultural land or vendor or of sufficient facts to induce a reasonably prudent
alienated private person by the State remain part of the man to inquire into the status of the title of the property in
alienable public domain. litigation. The presence of anything which excites or arouses
suspicion should then prompt the vendee to look beyond the
Does Regalian Doctrine negate native title? certificate and investigate the title of the vendor appearing
No. In the case of Cruz vs. Secretary of Environment and on the face of the said certificate. One who falls within the
Natural Resources, GR No. 135385, December 6, 2000, 347 exception can neither de denominated an innocent purchaser
SCRA 148, the Supreme Court institutionalized the for value nor a purchaser in good faith and, hence, does not
recognition of the existence of native title to land, or merit the protection of the law.
ownership of land by Filipinos by virtue of possession under a
claim of ownership since time immemorial and independent
of any grant from the Spanish crown, as an exception to the
theory of jura regalia.

Purpose of the Torrens system

The real purpose of the Torrens system as expressed in the
Legarda vs. Saleeby, GR No. 8936, October 2, 1915, is to quiet
title to land; to put a stop forever to any question of the
legality of the title, except claims which were noted at the
time of the registration in the certificate, or which may arise
subsequent thereto.

Principle of indefeasibilty:
The rights of all the world are foreclosed by the decree of
registration. The title once registered, with very few
exceptions, should not thereafter be impugned, altered,
changed, modified, enlarged or diminished, except in some
direct proceeding permitted by law.
However, the Torrens system does not furnish a shield for
fraud, nor permit one to enrich himself at the expense of
others, otherwise its acceptability is impaired. The
indefeasibility of a title does not attach to titles secured by
fraud and misrepresentation. (Baguio vs. Republic, GR No.
119682, January 21, 1999)

Mirror doctrine
Mirror doctrine provides that every person dealing with
registered land may safely rely on the correctness of the
certificate of title issued therefor and is in no way obliged to
go beyond the certificate to determine the condition of the
property. Consequently, every registered owner and every
subsequent purchaser for value in good faith holds the title to
the property free from encumbrances except those noted in
the certificate. As such, a defective title, or one the
procurement of which is tainted with fraud and
misrepresentation may be the source of a completely legal
and valid title, provided that the buyer is an innocent third
person, who in good faith, relied on the correctness of the
certificate of title, or an innocent purchaser for value (Dy vs.
Aldea, GR No. 219500, August 9, 2017, citing Locsin vs. Hizon,
GR No. 204369, September 17, 2014)