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I. Torrens System of Land Registration A. Background 1. Import and Purpose Legarda v. Saleeby, G.R. No. L-8936 October 2, 1915 Legarda abd saleeby are owners of adjoining lots separated by a stonewall located in legarda’s lot. In 1906, legarda petitioned in the court of land registration for the registration of their lot which was granted. It included the lot of the stonewall. In 1912 saleeby petitioned for the registration of their land and was granted. It also included the lot of the stonewall. Upon discovery, legarda filed before the CLR for an adjustment and correction of error. The lower court denied the petition based on the reason that the action is of a judicial proceeding and its judgment is binding upon all the parties. For failure of legarda to opposed the registration, they had lost the land. WON the defendants own the lot in question. NO. The real purpose of that system 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 a title is registered the owner may 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. The primary and fundamental purpose of the torrens system is to quiet title. If the holder of a certificate cannot rest secure in this registered title then the purpose of the law is defeated Republic v. Umali, G.R. No. 80687 April 10, 1989 The land in question was originally purchased on installment from the govt by Bobadilla who transferred her rights to the cenizal. In 1971, the assignees signed a joint affidavit filed to the bureau of lands to support their claims that they are entitles to issuance of certificate. Sec. of ANR xecuted a deed in their favor. A complaint was files by the state on ground of forgery and fraud. When the complaint of reversion was filed, miclat, Pulido, naval were the registered owners. Miclat and Pulido denied participation in the joint affidavit and acquired the property in good faith and for value. Miclat filed for dismissal, govt is not a real party in interest as the subject land is already covered under the torrens system. WON the land may be reverted. There is no allegation in the complaint 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. Under Sec. 39. 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

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I. Torrens System of Land RegistrationA. Background1. Import and Purpose Legarda v. Saleeby, G.R. No. L-8936 October 2, 1915Legarda abd saleeby are owners of adjoining lots separated by a stonewall located in legardas lot. In 1906, legarda petitioned in the court of land registration for the registration of their lot which was granted. It included the lot of the stonewall. In 1912 saleeby petitioned for the registration of their land and was granted. It also included the lot of the stonewall. Upon discovery, legarda filed before the CLR for an adjustment and correction of error. The lower court denied the petition based on the reason that the action is of a judicial proceeding and its judgment is binding upon all the parties. For failure of legarda to opposed the registration, they had lost the land.WON the defendants own the lot in question.NO. The real purpose of that system 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 a title is registered the owner may 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.The primary and fundamental purpose of the torrens system is to quiet title. If the holder of a certificate cannot rest secure in this registered title then the purpose of the law is defeated

Republic v. Umali, G.R. No. 80687 April 10, 1989The land in question was originally purchased on installment from the govt by Bobadilla who transferred her rights to the cenizal. In 1971, the assignees signed a joint affidavit filed to the bureau of lands to support their claims that they are entitles to issuance of certificate. Sec. of ANR xecuted a deed in their favor. A complaint was files by the state on ground of forgery and fraud. When the complaint of reversion was filed, miclat, Pulido, naval were the registered owners. Miclat and Pulido denied participation in the joint affidavit and acquired the property in good faith and for value. Miclat filed for dismissal, govt is not a real party in interest as the subject land is already covered under the torrens system.WON the land may be reverted.There is no allegation in the complaintfiled 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. Under Sec. 39. 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. Pino v. CA, G.R. No. 94114 June 19, 1991The land in question was acquired by spouse gaffud in 1924. Under the OCT Rafaela and his 2sons are co-owners. The said lot was sold to Rafaela through a deed of transfer. Rafaela sold a portion to Pascua (lot A). Rafaela sold to pino the said lot B and a TCT was issued in favor of pino. One of the sons filed for the nullity of the sale. RTC ruled in favor of defendants and was affirmed by CA.WON the sale is void.The rule applicable to this controversy is well-settled. Where the certificate of title is in the name of the vendor when the land is sold, the vendee for value has the right to rely on what appears on the certificate of title. In the absence of anything to excite or arouse suspicion, said vendee is under no obligation to look beyond the certificate and investigate the title of the vendor appearing on the face of said certificate. The rationale for the rule is stated thus:The main purpose of the Torrens' System is to avoid possible conflicts of title to real estate and to facilitate transactions relative thereto by giving the public the right to rely upon the face of a Torrens Certificate of Title and to dispense with the need of inquiring further, except when the party concerned had actual knowledge of facts and circumstances that should impel a reasonably cautious man to make such further inquiry. (Pascua v. Capuyoc, 77 SCRA 78) Thus, where innocent third persons relying on the correctness of the certificate thus issued, acquire tights over the property, the court cannot disregard such rights. (Director of Land v. Abache, et al., 73 Phil. 606)In the case at bar, the evidence on record discloses that when petitioner purchased the subject property on June 10, 1970, the title thereto (TCT No. T-32683) was in the name of her vendorRafaela Donato alone. Traders Royal Bank v. CA, G.R. No. 114299.September 24, 1999Capays executed ma mortgage in favor of traders bank which covered the land in dispute. Failure to pay bank instituted extra judicial foreclosure. Capay filed a prohibition and preliminary injunction before the CFI alleging they did not receive the proceeds of the loan. Capay filed a notice of lis pendens over the property. The property was sold to the bank as the highest bidder. TCT was issued to the bank without the notice of lis pendens being carried over. Capay filed for the recovery of the property. CFI ruled in favor of the capay. The bank appealed to CA, while pending the bank sold the property to Santiago and Santiago sold the property to alcantara and his co-owners and again sold to 6 different buyers. CA affirmed in toto.WON the capays has a better right over the respondents.The non-bank respondents had a right to rely on what appeared on the face of the title of their respective predecessors-in-interest, and were not bound to go beyond the same.To hold otherwise would defeat one of the principal objects of the Torrens system of land registration, that is, to facilitate transactions involving lands.The main purpose of the torrens system is to avoid possible conflicts of title to real estate and to facilitate transactions relative thereto by giving the public the right to rely upon the face of a Torrens certificate of title and to dispense with the need of inquiring further, except when the party concerned has actual knowledge of facts and circumstances that should impel a reasonably cautious man to make such further inquiry.Where innocent third persons, relying on the correctness of the certificate of title thus issued, acquire rights over the property, the court cannot disregard such rights and order the total cancellation of the certificate.The effect of such an outright cancellation would be to impair public confidence in the certificate of title, for everyone dealing with property registered under the Torrens system would have to inquire in every instance as to whether the title has been regularly or irregularly issued by the court.Every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and the law will in no way oblige him to go beyond the certificate to determine the condition of the property. Casimiro Devt. Corp. v. Mateo, G.R. No. 175485. July 27, 2011In 1988, petitioner purchased from China Bank the land in question which was previously sold by the mother of Mateo to RodolfoPewho in turn constituted a mortgage on the property in favor of China Bank as security for a loan. China Bank foreclosed the mortgage and consolidated its ownership of the property after Rodolfo failed to redeem. A TCT was issued in the name of China Bank.In 1991, CDC brought an action for unlawfuldetatineragainst the respondents siblings.Respondent counters that CDC acquired the property from China Bank in bad faith because it had actual knowledge of the possession of the propertyby the respondent and his siblings.WONCDC was an innocent purchaser for value.One who dealswith property registered under the Torrens system need not go beyond the certificate of title, but only has to rely onthe certificate of title.He is charged with notice only of such burdens and claimsas are annotated on the title. China Banks TCTs was a clean title, that is, it was free from any lien or encumbrance, CDC had the right to rely, when it purchased the property, solely upon the face of the certificate of title in the name of China Bank.The respondents siblings possession did not translate to an adverse claim of ownership. They even characterized their possession only as that of mere agricultural tenants. Under no law was possession grounded on tenancy a status that might create a defector inflict a law in the title of the owner.CDC having paid the full and fair price of the land, was an innocent purchaserfor value. The TCT in the name of CDC was declared valid and subsisting.2. Characteristics Bars all prior claims not registered Best Evidence of Ownership Imprescriptible - No title to registered land in derogation of the title of the registered owner shall be acquired by prescription or adverse possession. (Sec. 47, P.D. 1529) Indefeasible - After the lapse of one year from the entry of the decree of registration, said the decree of registration and the certificate of title issued shall become incontrovertible. (Sec 32, P.D. 1529) Integrity of titles not subject to collateral attack - A certificate of title shall not be subject to collateral attack. It cannot be altered, modified, or cancelled except in a direct proceeding in accordance with law. (Sec. 48, P.D. 1529) Notice to the Whole World Presumption that title is regular and valid Reliance on titles3. Nature of the Proceedings1. Laburada v. LRA, G.R. No. 101387.March 11, 1998Sps laburada applied for the registration of lot 3-a located in madaluyong which was approved by the trial court. Upon motion of the sps , the trial court ordered LRA to issue the corresponding decree of registration. However the LRA refused. Hence sps filed for mandamus. Based on the record, some portions of the lot 3-a which is sought to be registered is covered by certificates issued prior to the decree.WON LRA may be compelled by mandamus.Court has no jurisdiction to decree again the registration of land already decreed in an earlier land registration case and a second decree for the same land is void. This is so, because when once decreed by a court of competent jurisdiction, the title to the land thus determined is already a res judicata binding on the whole world, the proceedings being in rem. The court has no power in a subsequent proceeding (not based on fraud nor within the statutory period) to adjudicate the same title in favor of another person.Furthermore, the registration of the property in the name of the first registered owner in the Registration Book is a standing notice to the world that said property is already registered in his name. Hence, the latter applicant is chargeable with notice that the land he applied for is already covered by a title so he has no right whatsoever.In other words, the first proceedings are in rem which binds the second proceedings.As the title of the respondents, who hold certificates of title under the Land Registration Act becomes indefeasible, it follows that the Court of First Instance has no power or jurisdiction to entertain proceedings for the registration of the same parcels of land covered by the certificates of title of the respondents.2. Secretary of DENR v. Yap, G.R. No. 167707. October 8, 2008

4. In Relation to the Public Land Act (CA 141, as amended)1. Republic v. Herbieto, G.R. No. 156117. May 26, 2005]The CA overlooked the difference between the Property Registration Decree and the Public Land Act. Under the PRD, there already exists a title which is confirmed by the Court; while under the PLA, the presumption always is that the land applied for pertains to the State, and that the occupants and possessors only a claim an interest in the same by virtue of their imperfect title or continous, open and notorious possession [since June 12, 1945 or earlier].Since the subject lands are alienable and disposable lands of the public domain, the applicants may acquire title thereto only under the PLA.Applicants could not acquire land through adverse possession since the land was only classified as alienable in 1963 AND their possession only started in 1950. (Note: Substantial requirements for public lands are in the PLA but the procedural requirements are in the PRD.)Civil Code provisions on prescription, which is subject to confirmation under the PRD, in general applies to all types of land. However, excluded therefrom are lands of the public domain which are covered by the PLA [special law v. general law]2. Heirs of Lopez v. De Castro, G.R. No. 112905. February 3, 2000A proceeding in rem, such as land registration proceedings, requires constructive seizure of the land as against all persons, including the State, who have rights to or interests in the property. Constructive seizure of the land for registration is effected through publication of the application for registration and service of notice to affected parties.Consequently, when respondents De Castro filed their own application for registration of the same parcel of land in the Tagaytay CFI branch, strictly speaking, it could no longer entertain the application for registration as the res involved had been constructively seized by the Cavite CFI branch. Be that as it may, the Court is not persuaded that the registration proceedings instituted by private respondents should be nullified by reason of the fact that the Cavite City branch of the same court was already proceeding with another registration case for the same piece of land.In land registration proceedings, all interested parties are obliged to take care of their interests and to zealously pursue their objective of registration on account of the rule that whoever first acquires title to a piece of land shall prevail. To illustrate, where more than one certificate of title is issued over the land, the person holding a prior certificate is entitled to the land as against a person who relies on a subsequent certificate. It should be stressed that said rule refers to the date of the certificate of title and not to the date of filing of the application for registration of title. Hence, even though an applicant precedes another, he may not be deemed to have priority of right to register title. As such, while his application is being processed, an applicant is duty-bound to observe vigilance and to take care that his right or interest is duly protected.