1.

Facts accdg to Petitioner: Petitioner filed a Complaint for partition w/ RTC, alleging that he
purchased 1/4 of the land of Federico Pugao. Petitioner paid Federico installments which totaled
to P6K. When the mortgage was released, petitioner demanded the execution of a deed of
absolute sale. Instead, Federico proposed to mortgage the property to petitioner as security for a
P10K loan, payable in 3 months, and upon payment of the loan the deed of absolute sale would
be executed. When Petitioner asked for the partition of the lot Federico refused and sent a notice
of eviction against petitioner. Facts according to Federico: He allowed petitioner and his niece to
occupy 1/4 of his lot, and admitted that he executed in favor of petitioner a deed of REM. The
loan was paid, mortgage cancelled. · Petitioner made him sign pages of what the former told him
to be parts of the REM. ISSUE: WON the sale was valid
2. RULING: YES. Respondents' claim is that the sale is voidable, and not void, because of mistake
and/or fraud. Nevertheless, one of the respondents testified that she was aware of the sale way
back in 1984. Yet, none of them took any action to annul the deed within the prescribed 4-year
period which expired in 1988. CA ruled that petitioner's cause of action has prescribed following
its conclusion that petitioner's action is actually one for specific performance, not partition.
Interestingly, petitioner suddenly changed tack and declared that his original action was indeed
an action for specific performance. He should not have gone that far. His objective is to make
Federico honor their contract and perform his obligation to deliver a separate title covering the lot
he sold to him but which can be done only after the portion is segregated from the rest of
Federico's property. Petitioner's action before the RTC was properly captioned as one for partition
because there are sufficient allegations in the complaint that he is a co-owner. A co-owner cannot
point to a specific portion of the property as his own because his share remains intangible. The
description "undivided 1/4 portion" shows that the portion sold is still undivided and not sufficiently
identified. This is the reason why petitioner was constrained to cause the survey of the property.
As a co-owner, petitioner has the right to demand partition, a right which does not prescribe.
Ownership of the thing sold is acquired only from the time of delivery, either actual or
constructive. Article 1498 provides that when the sale is made through a public instrument, the
execution shall be equivalent to the delivery. In view of the delivery in law, coupled with
petitioner's actual occupation of the portion where his house stands, all that is needed is its
segregation from the rest of the property.
3. Locsin was the registered owner of a lot covered by TCT. Locsin filed an ejectment case against
Aceron to recover possession. Eventually, the two entered into a compromise agreement. Locsin
went to the US without knowing whether Aceron has complied with the compromise
agreement. After discovering that her TCT was missing, Locsin filed a petition for administrative
reconstruction to secure a new one. Marylou Bolos had TCT cancelled and then secured a new
one in her favor by registering a Deed of Absolute Sale allegedly executed by Locsin. Bolos sold
to Bernardo Hizon, but it was titled under his son’s (Carlos Hizon) name. Locsin, sent Carlos a
letter requesting return of property since her signature in the deed of sale w/ Bolo was a
forgery. Carlos denied Locsin’s request, claiming that he was unaware of any defect in Bolos’
title and he is, thus, an innocent purchaser for value. Carlos had already sold to his sister and her
husband (spouses Guevara). ISSUE: WON Carlos and Sps. are innocent purchasers for value
4. RULING: NO. An innocent purchaser for value is one who buys the property of another without
notice that some other person has a right to or interest in it, and who pays a full and fair price at
the time of the purchase or before receiving any notice of another person’s claim. As such, a
defective title–– or one the procurement of which is tainted with fraud and misrepresentation––
may be the source of a completely legal and valid title, provided that the buyer is an innocent third
person who, in good faith, relied on the correctness of the certificate of title, or an innocent
purchaser for value. Complementing this is the mirror doctrine which echoes the doctrinal rule
that every person dealing with registered land may safely rely on the correctness of the certificate
of title issued therefor and is in no way obliged to go beyond the certificate to determine the
condition of the property.
Exceptions:
1. when the party has actual knowledge of facts and circumstances that would impel a reasonably
cautious man to make such inquiry
2. when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient
facts to induce a reasonably prudent man to inquire into the status of the title of the property in
litigation.
Bolos’ certificate of title was concededly free from liens and encumbrances on its face. However,
the failure of Carlos and the spouses Guevara to exercise the necessary level of caution in light
of the factual milieu surrounding the sequence of transfers from Bolos to respondents bars the
application of the mirror doctrine.