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Case 8 Heir of Trinidad de Leon Vda de Roxas Vs CA

This case involves a dispute over land titles between the heirs of Roxas and Meycauayan Management. The Supreme Court previously ruled that the original title holder, Maguesun Management, obtained the land's registration through actual fraud. Meycauayan claims to have purchased the land in good faith from Maguesun. However, the Court finds that Meycauayan cannot be considered a purchaser in good faith because it was aware of the ongoing legal dispute over the land's ownership prior to purchasing based on its own checks with the local courts. As Maguesun's successor, Meycauayan is also bound by the prior ruling against Maguesun that found its title fraudulent. Therefore, M

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440 views1 page

Case 8 Heir of Trinidad de Leon Vda de Roxas Vs CA

This case involves a dispute over land titles between the heirs of Roxas and Meycauayan Management. The Supreme Court previously ruled that the original title holder, Maguesun Management, obtained the land's registration through actual fraud. Meycauayan claims to have purchased the land in good faith from Maguesun. However, the Court finds that Meycauayan cannot be considered a purchaser in good faith because it was aware of the ongoing legal dispute over the land's ownership prior to purchasing based on its own checks with the local courts. As Maguesun's successor, Meycauayan is also bound by the prior ruling against Maguesun that found its title fraudulent. Therefore, M

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ailynvds
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Case 8 HEIRS OF TRINIDAD DE LEON VDA. DE ROXAS vs.

COURT OF APPEALS and MAGUESUN MANAGEMENT AND


DEVELOPMENT CORPORATION
G.R. No. 138660 February 5, 2004

Facts: A petition to set aside the decree of registration over two unregistered parcels of land in Tagaytay City granted to corporation
respondent before the RTC on the ground of actual fraud was filed by Trinidad de Leon Vda. De Roxas. This was granted by the
Supreme Court, on appeal (in a previous case). Subsequently, Meycauyan filed a petition to intervene in the said case, alleging that it
purchased three parcels of land from Maguesun which form part of the property awarded to the heirs of Roxas and that since it is a
purchaser in good faith and for value, the Court should afford it the opportunity to be heard, that the adverse decision in the previous
case cannot impair its rights as a purchaser in good faith and for value. This was denied.

The heirs of Roxas then filed a Motion for Issuance of Writ of Possession with the land registration court, after their motion for
clarification was granted. Meycauayan filed a Complaint for reconveyance, damages and quieting of title with the trial court. Such
complaint is almost an exact reproduction of the Petition for Intervention filed by Meycauyan. Consequently, the trial court dismissed for
lack of merit Meycauayan's complaint for reconveyance, damages and quieting of title, holding that the nullity of the OCT of Maguesun
where Meycauyan is not a party in the suit and which is the source of Meycauayan's title, is now res judicata.

Issue: Whether Meycauyan’s action for reconveyance, damages and quieting of title can be validly tried by the court

Held: No

Courts will simply refuse to reopen what has been decided. They will not allow the same parties or their privies to litigate anew a
question, once it has been considered and decided with finality. Litigations must end and terminate sometime and somewhere. The
effective and efficient administration of justice requires that once a judgment has become final, the prevailing party should not be
deprived of the fruits of the verdict by subsequent suits on the same issues filed by the same parties.

This is in accordance with the doctrine of res judicata which has the following elements: (1) the former judgment must be final; (2) the
court which rendered it had jurisdiction over the subject matter and the parties; (3) the judgment must be on the merits; and (4) there
must be between the first and the second actions, identity of parties, subject matter and causes of action.

The application of the doctrine of res judicata does not require absolute identity of parties but merely substantial identity of parties.
 There is substantial identity of parties when there is community of interest or privity of interest between a party in the first and
a party in the second case even if the first case did not implead the latter.

The Court ruled in the previous case that Meycauayan's predecessor-in-interest, Maguesun, committed actual fraud in obtaining the
decree of registration of the subject properties. The decision is such case binds Meycauayan under the principle of "privity of interest"
since it was a successor-in-interest of Maguesun.

Meycauayan, however, insists that it was a purchaser in good faith because it had no knowledge of any pending case involving the lots.
Meycauayan claims that the trial court had already canceled the notice of lis pendens on the titles when it purchased the lots from
Maguesun.

In its Memorandum, Meycauayan stresses that to ensure the authenticity of the titles and the annotations appearing on the titles,
particularly the cancelation of the notice of lis pendens, Meycauayan checked with the Register of Deeds and the Regional Trial Court
of Tagaytay City.

Since Meycauayan checked with the Regional Trial Court of Tagaytay City, Meycauayan then had actual knowledge, before it
purchased the lots, of the pending case involving the lots despite the cancelation of the notice of lis pendens on the titles.

Furthermore, the Roxas family has been in possession of the property uninterruptedly through their caretaker, Jose Ramirez, who
resided on the property. Where the land sold is in the possession of a person other than the vendor, the purchaser must go beyond the
certificates of title and make inquiries concerning the rights of the actual possessor.

Meycauayan, therefore, cannot invoke the right of a purchaser in good faith and could not have acquired a better right than its
predecessor-in-interest. This Court has already rejected Meycauayan’s claim that it was a purchaser in good faith when it ruled in G.R.
No. 118436 that there had been no intervening rights of an innocent purchaser for value involving the lots in dispute.

Indeed, one who buys property with full knowledge of the flaws and defects of the title of his vendor and of a pending litigation over the
property gambles on the result of the litigation and is bound by the outcome of his indifference. A purchaser cannot close his eyes to
facts which should put a reasonable man on guard and then claim that he acted in good faith believing that there was no defect on the
title of the vendor.
__________________________________________________________________________________________

Gen. Rule: Indefeasibility of Title


Exceptions to Indefeasibility
(1) Statutory Liens and Restrictions
(2) Deferred indefeasibility
(3) Reconveyance
A legal and equitable remedy granted to the rightful land owner of land which has been wrongfully or erroneously registered in the
name of another for purpose of compelling the latter to transfer or reconvey the land to him.
Prescription of Action for Reconveyance
i) Action based on Fraud - 10 years from the issuance of title or date of registration of deed.
ii) Res Judicata - Court cancels the title
(4) Laches
(5) Reversion
(6) Caveat Emptor Although it is a recognized principle that a person dealing with registered land need not go beyond its certificate of
Title, it is expected from the purchaser of a valued property to inquire first into the status or nature of possession of the occupant,
whether or not the occupants possess the land en concepto de dueño, in concept of an owner.

The rule of caveat emptor requires the purchasers to be aware of the supposed title of the vendor and one who buys without checking
the vendor’s title takes all the risks and losses consequent to such failure. Possession by people other than the vendor without making
inquiry, cannot be regarded as bona fide purchaser in good faith.

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