PRESUMPTION OF INNOCENT PURCHASER FOR VALUE IS DISPUTABLE
The presumption that a holder of a Torrens title is an innocent purchaser for value is disputable
and may be overcome by contrary evidence. Once a prima facie case disputing this presumption is
established, the adverse party cannot simply rely on the presumption of good faith and must put
forward evidence that the property was acquired without notice of any defect in its title.
(Sindophil, Inc. v. Republic,G.R. No. 204594, November 21, 2018 )
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PRESUMPTION OF INNOCENT PURCHASER FOR VALUE IS DISPUTABLE
The presumption that a holder of a Torrens title is an innocent purchaser for value is disputable
and may be overcome by contrary evidence. Once a prima facie case disputing this presumption is
established, the adverse party cannot simply rely on the presumption of good faith and must put
forward evidence that the property was acquired without notice of any defect in its title.
(Sindophil, Inc. v. Republic,G.R. No. 204594, November 21, 2018 )
Sindophil, Inc. v. Republic
G.R. No. 204594, November 21, 2018
Leonon, J.
FACTS:
This case involves a 2,791-square-meter parcel of land (Tramo property) located on Aurora
Boulevard, Pasay City, currently in Sindophil's possession. Sindophil anchors its right to the Tramo
property on TCT No. 132440, which was purportedly issued by the Register of Deeds of Pasay
City.
Republic filed a Complaint for revocation, annulment, and cancellation of certificates of title before
RTC Pasay, and impleaded Sindophil as one of the defendants.
In its Complaint, the Republic alleged that per TCT No. 10354, issued by the Register of Deeds of
Pasay City, the Tramo property was initially registered under the name of Teodoro on November
12, 1964. Teodoro then sold it to a certain Reynaldo Puma (Puma), causing the cancellation of
TCT No. 10354 and the issuance of TCT No. 128358. Subsequently, Puma sold it to a certain
Lourdes Ty (Ty). Puma's TCT No. 128358 was cancelled and TCT No. 129957 was issued to Ty.
Finally, on May 3, 1991,Ty sold the property to Sindophil, causing the cancellation of TCT No.
129957 and the issuance of TCT No. 132440 to Sindophil on March 24, 1993.
The Republic claimed that TCT No. 10354 in the name of Teodoro was "spurious or of do ubtful
authenticity." And as as found by the Regional Trial Court: “Record shows that Certificate of Title
No. 6735, wherein the lot claimed by defendant, Marcelo R. Teodoro, lot 3270-B, is derived
therefrom, is under the name of the Republic of the Philippines, dated October 17, 1913. Nothing
in the subsequent annotations was under the name of any of the defendants and neither the
subject TCT No. 10354”
Sindophil contended that they were innocent purchasers for value and, in the absence of evidence
to the contrary, reconveyance should not lie. Arguing that the Republic had no cause of action
against them, they prayed for the dismissal of the Complaint.
ISSUE:
Whether or not Sindophil’s defense of innocent purchaser for value is tenable.
HELD:
No, Sindophil’s defense of innocent purchaser for value is not tenable.
The presumption that a holder of a Torrens title is an innocent purchaser for value is disputable
and may be overcome by contrary evidence. Once a prima facie case disputing this presumption is
established, the adverse party cannot simply rely on the presumption of good faith and must put
forward evidence that the property was acquired without notice of any defect in its title.
With the Republic having put forward evidence that the Tramo property claimed by Sindophil
belongs to the Republic, the burden of evidence shifted to Sindophil to prove that its title to it was
valid. Concomitantly, it had the burden of proving that it was indeed a buyer in good faith and for
value. As this Court said in Baltazar v. Court of Appeals, "the burden of proving the status of a
purchaser in good faith and for value lies upon him who asserts that status" and "in discharging
that burden, it is not enough to invoke the ordinary presumption of good faith, i.e., that everyone is
presumed to act in good faith. The good faith that is [essential here] is integral with the very status
which must be proved."
Unfortunately for Sindophil, it utterly failed to discharge the burden of evidence because its
counsel failed to attend the scheduled initial presentation of evidence.
Further, looking at the records, the defects in Sindophil's title could be inferred from the
annotations in TCT No. 129957, the certificate of title held by Sindophil's immediate predecessor,
Ty. A certain Antonio C. Mercado had filed an adverse claim against Ty because the Tramo
property had been previously sold to him by Puma, Ty's predecessor. The alleged double sale
should have prompted Sindophil to look into Puma's title, TCT No. 128358, where it can be
gleaned that Teodoro likewise filed an adverse claim. These annotations show that the Tramo
property is controversial and has been the subject of several adverse claims, belying Sindophil's
contention that it acquired the property in good faith.
