SC to land buyers: Verify titles, Registry of Deeds records
MANILA, Philippines – The Supreme Court (SC) has ruled that clean land titles alone are not enough protection for buyers, ruling that they must thoroughly inspect Registry of Deeds records to avoid falling victim to fraudulent transactions.
This was based on the decision written by Associate Justice Alfredo Benjamin Caguioa when the SC upheld a ruling that voided the land titles of spouses Orencio and Eloise Manalese.
The land titles of the Manalese spouses were voided after the SC found that they failed to conduct due diligence when buying land from a certain Carina Pinpin, who acquired the title through fraud.
“Relying solely on a certificate of title is insufficient, especially if there are signs of fraud or irregularity,” the SC Public Information Office said, citing the decision.
“Buyers who ignore suspicious facts cannot claim to be in good faith,” it added.
The case involved properties from the Ferreras family, which Carine Pinpin sold to the Manaleses using duplicate titles obtained through false affidavits of loss and a forged deed of sale from the deceased owners.
Despite these red flags, including an unusually low purchase price of P250,000 and notarized documents dated after the original owners had died, the Manaleses proceeded with the sale and registered the titles under their names.
“Since these transactions were all documented in the Registry of Deeds, Spouses Manalese are deemed to have presumptive knowledge of the defects in Pinpin’s title and cannot claim ignorance,” the SC ruled.
The Regional Trial Court (RTC) and Court of Appeals (CA) found the couple to be buyers in bad faith for failing to investigate the property’s history despite the clear warning signs made public in the Registry of Deeds — which the SC upheld.
Meanwhile, Associate Justice Henri Inting agreed in a concurring opinion that the buyers were not innocent.
However, he warned that requiring ordinary buyers to probe beyond a clean title “places an undue burden on ordinary buyers and undermines the reliability of certificates of title.”
