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    Republic v. Umali Digest

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    Nikki Estores Gonzales
    The Supreme Court ruled in favor of the new landowners, finding that: 1) There was no evidence that the new owners obtained the land through forgery or fraud. As innocent transferees for value, they were protected under the Torrens system. 2) Under the Land Registration Act, owners of registered land can hold it free of all encumbrances except those noted on the title. 3) Once land is registered under the Torrens system, the owner can rest secure without the risk of losing the land, unless a claim was noted on the original title or arises later. The government no longer has jurisdiction over the privately owned registered land.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Republic v. Umali Digest

    Uploaded by

    Nikki Estores Gonzales
    1K views2 pages
    The Supreme Court ruled in favor of the new landowners, finding that: 1) There was no evidence that the new owners obtained the land through forgery or fraud. As innocent transferees for value, they were protected under the Torrens system. 2) Under the Land Registration Act, owners of registered land can hold it free of all encumbrances except those noted on the title. 3) Once land is registered under the Torrens system, the owner can rest secure without the risk of losing the land, unless a claim was noted on the original title or arises later. The government no longer has jurisdiction over the privately owned registered land.

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    Republic v. Umali Digest

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    The Supreme Court ruled in favor of the new landowners, finding that: 1) There was no evidence that the new owners obtained the land through forgery or fraud. As innocent transferees for value, they were protected under the Torrens system. 2) Under the Land Registration Act, owners of registered land can hold it free of all encumbrances except those noted on the title. 3) Once land is registered under the Torrens system, the owner can rest secure without the risk of losing the land, unless a claim was noted on the original title or arises later. The government no longer has jurisdiction over the privately owned registered land.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    1K views2 pages

    Republic v. Umali Digest

    Uploaded by

    Nikki Estores Gonzales
    The Supreme Court ruled in favor of the new landowners, finding that: 1) There was no evidence that the new owners obtained the land through forgery or fraud. As innocent transferees for value, they were protected under the Torrens system. 2) Under the Land Registration Act, owners of registered land can hold it free of all encumbrances except those noted on the title. 3) Once land is registered under the Torrens system, the owner can rest secure without the risk of losing the land, unless a claim was noted on the original title or arises later. The government no longer has jurisdiction over the privately owned registered land.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Republic v Umali

    G.R. No. 80687, April 10, 1989

    PONENTE

    CRUZ, J.:

    FACTS

    The land situated in Tanza, Cavite which consists of 78,865 square meters was originally
    purchased on installment from the government on July 1, 1910 by Florentina Bobadilla, who allegedly
    transferred her rights thereto in favor of Martina, Tomasa, Gregorio and Julio, all surnamed Cenizal, in
    1922. 2 Tomasa and Julio assigned their shares to Martina, Maria and Gregorio. In 1971 these three
    assignees purportedly signed a joint affidavit which was filed with the Bureau of Lands to support their
    claim that they were entitled to the issuance of a certificate of title over the said land on which they said
    they had already made full payment. On the basis of this affidavit, the Secretary of Agriculture and
    Natural Resources executed Deed No. V-10910 (Sale Certificate No. 1280) on September 10, 1971, in
    favor of the said affiants.

    A complaint for reversion was filed on October 10, 1985 when the registered owners of the land,
    following several transfers, were Remedios Micla, Juan C. Pulido, and Rosalina, Luz and Enrique Naval.
    They asked to return the property to the State on the aforestated grounds of forgery and fraud. The
    plaintiff claimed that Gregorio Cenizal having died on February 25, 1943, and Maria Cenizal on January
    8, 1959, they could not have signed the joint affidavit dated August 9, 1971, on which Deed No. V-10910
    (Sale Certificate No. 1280) was based.

    In their answer, Pulido and the Navals denied any participation in the join affidavit and said they
    had all acquired the property in good faith and for value. By way of affirmative defenses, they invoked
    estoppel, laches, prescription and res judicata. For her part, Miclat moved to dismiss the complaint,
    contending that the government had no cause of action against her because there was no allegation that
    she had violated the plaintiffs right, that the government was not the real party-in-interest because the
    subject land was already covered by the Torrens system, and that in any event the action was barred by
    prescription or laches.

    ISSUE

    Whether or not the land under the new owners are obtained thru forgery and fraud and subject to
    return the property to the State

    HELD

    We agree with the contention that there is no allegation in the complaint 13 filed by the petitioner
    that any one of the defendants was privy to the forged joint affidavit or that they had acquired the subject
    land in bad faith. Their status as innocent transferees for value was never questioned in that pleading. Not
    having been disproved, that status now accords to them the protection of the Torrens System and renders
    the titles obtained by them thereunder indefeasible and conclusive. The rule will not change despite the
    flaw in TCT No. 55044.

    Section 39 of the Land Registration Act clearly provided: Every person receiving a certificate of
    title in pursuance of a decree of registration, and every subsequent purchaser of registered land who takes
    a certificate of title for value in good faith shall hold the same free of all encumbrance except those noted
    on said certificate.

    The real purpose of the Torrens System of land registration 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
    registration in the certificate, or which may arise subsequent thereto. That being the purpose of the law, it
    would seem that once the title was registered, the owner might rest secure, without the necessity of
    waiting in the portals of the court, or sitting in the "mirador de su casa," to avoid the possibility of losing
    his land.

    Page 1 of 2
    The difference between them and the private respondents is that the latter acquired the land in
    question not by direct grant but in fact after several transfers following the original sale thereof to
    Bobadilla in 1910. The presumption is that they are innocent transferees for value in the absence of
    evidence to the contrary. The petitioner contends that it was Pedro Miclat who caused the falsification of
    the joint affidavit, but that is a bare and hardly persuasive allegation, and indeed, even if true, would still
    not prove any collusion between him and the private respondents. The mere fact that Remedios Miclat
    was the daughter and heiress of Miclat, without more, would not necessarily visit upon her the alleged
    sins of her father.

    The land being now registered under the Torrens system in the names of the private respondents,
    the government has no more control or jurisdiction over it. It is no longer part of the public domain or, as
    the Solicitor General contends as if it made any difference of the Friar Lands. The subject property
    ceased to be public land when OCT No. 180 was issued to Florentina Bobadilla in 1910 or at the latest
    from the date it was sold to the Cenizals in 1971 upon full payment of the purchase price. As private
    registered land, it is governed by the provisions of the Land Registration Act, now denominated the
    Property Registration Decree, which applies even to the government.

    Page 2 of 2

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