SC: Land Buyers Must Check Both Title and Registry of Deeds Records

March 6, 2025

The Supreme Court (SC) has ruled that land buyers must verify ownership by checking the certificate of title and reviewing the records in the Registry of Deeds to avoid fraudulent transactions.

In a Decision penned by Associate Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division upheld the rulings of the Regional Trial Court (RTC) and Court of Appeals (CA), which voided the land titles of Orencio and Eloisa Manalese (Spouses Manalese).  The SC found that they failed to conduct due diligence when buying land from Carina Pinpin (Pinpin), who acquired her titles through fraud.

Spouses Manalese purchased two parcels of land from Pinpin, who presented certificates of title in her name and claimed to have bought the properties from the original owners, the late Narciso and Ofelia Ferreras (Ferreras).  Pinpin showed a deed of sale as proof of her ownership, which allowed Spouses Manalese to transfer the titles to their name.

However, Danilo Ferreras (Danilo), the administrator of the Ferreras estate, challenged the validity of these titles before the RTC, claiming the properties still legally belonged to the estate. He alleged that Pinpin fraudulently obtained duplicate titles by submitting a false affidavit of loss and a forged deed of sale. She then used these to sell the properties to Spouses Manalese a year later.

Spouses Manalese argued that they were innocent buyers who relied on what appeared to be clean titles.

However, the RTC and CA ruled that the spouses were buyers in bad faith because they failed to investigate the property’s ownership history despite warning signs. First, the deed of sale presented by Pinpin was executed and notarized after the original owners were already deceased. Second, Pinpin purchased the properties for only PHP 250,000.00 but sold them for PHP 3,300,000.00 – a massive increase in value.

The SC upheld the lower courts’ findings, stressing that buyers must check both the certificate of title and the Registry of Deeds records before purchasing land.  Relying solely on a certificate of title is insufficient, especially if there are signs of fraud or irregularity.

The SC ruled that buyers who ignore suspicious facts cannot claim to be in good faith. In this case, Spouses Manalese failed to investigate despite multiple warning signs, making them liable for not exercising due diligence.

Under Presidential Decree (PD) No. 1529, or the Property Registration Decree, a re-issued title is only a duplicate and does not have the same legal weight as the original title. Buyers dealing with such titles must be careful, as any subsequent registration based on a forged duplicate title is invalid.

Since Spouses Manalese were dealing with duplicate certificates, they should have verified these with the Registry of Deeds, which would have revealed the fraudulent transactions.

The law also established that registration of interests in land serves as constructive notice to the public, meaning that recorded transactions are presumed to be known to anyone dealing with the property.  In this case, several key documents were already on record, including the affidavit of loss procured by Pinpin, the issuance of another set of duplicate titles, a second affidavit of loss by Zenaida Ferreras, and the nearly simultaneous registrations of these three annotations on the titles. 

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.

In his Separate Concurring Opinion, Associate Justice Henri Jean Paul B. Inting agreed that Spouses Manalese were not buyers in good faith, as several red flags should have prompted further inquiry. However, he raised concerns about requiring all buyers to investigate beyond a clean title, arguing that this places an undue burden on ordinary buyers and undermines the reliability of certificates of title.  (Courtesy of the SC Office of the Spokesperson)

This press release is prepared for members of the media and the general public by the SC Office of the Spokesperson as a simplified summary of the SC’s Decision. For the SC’s complete discussion of the case, please read the full text of the Decision in G.R. No. 254046 (Spouses Orencio S. Manalese and Eloisa B. Manalese, and Aries B. Manalese v. The Estate of the Late Spouses Narciso and Ofelia Ferreras, represented by its Special Administrator, Danilo S. Ferreras, November 25, 2024) at  https://sc.judiciary.gov.ph/254046-spouses-orencio-s-manalese-and-eloisa-b-manalese-and-aries-b-manalese-vs-the-estate-of-the-late-spouses-narciso-and-ofelia-ferreras-represented-by-its-special-administrator-danilo-s-fer/ ; and the Separate Concurring Opinion of Associate Justice Henri Jean Paul B. Inting at https://sc.judiciary.gov.ph/254046-separate-concurring-opinion-justice-henri-jean-paul-b-inting/.