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Fule Case LTD

1) Emilia de Legare owned land and a house according to the title, but signed a fraudulent deed of sale to her adopted son John without understanding it. John then sold the properties to petitioners Fule and Aragon. 2) Although the initial deed to John was fraudulent, he obtained a registered title, which he then transferred to the petitioners. Under the Torrens system, registration validates transfers and buyers do not need to explore further once a title is registered. 3) Therefore, the transfer to the petitioners was valid, as John acquired valid title once registered, which then passed to the petitioners by operation of law.
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0% found this document useful (0 votes)
228 views2 pages

Fule Case LTD

1) Emilia de Legare owned land and a house according to the title, but signed a fraudulent deed of sale to her adopted son John without understanding it. John then sold the properties to petitioners Fule and Aragon. 2) Although the initial deed to John was fraudulent, he obtained a registered title, which he then transferred to the petitioners. Under the Torrens system, registration validates transfers and buyers do not need to explore further once a title is registered. 3) Therefore, the transfer to the petitioners was valid, as John acquired valid title once registered, which then passed to the petitioners by operation of law.
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Fule vs.

De Lagare
28 February 1963, GR L-17951, 7 SCRA 351

Facts:
 Respondent Emilia E. de Legare was an owner of a parcel of land and a residential house erected thereon
as evidenced by TCT-21253 issued by the Office of the Register of Dees of the province of Rizal.
 On 29 March 1953, John W. Legare, respondent’s adopted son, exhibited a paper to the latter telling her to
sign it for him to be able to secure a certain sum of money from the US Veterans Administration.
 The said paper, unknown to Emilia who was illiterate, was a deed of sale over the properties in question in
favor of John W. Legare for the sum of P12,000, and acknowledged before a notary public.
 Thereafter, John W. Legare sold the properties to petitioners Conrado C. Fule and Lourdes F. Aragon. Thus,
a deed of absolute sale was executed in favor of the latter.
 Both deeds were then registered before the Register of Deed of the province of Rizal resulting to the
issuance of TCT-30126 in favor of John cancelling the TCT-21253. Subsequently, TCT-30127 was issued in
favor of Fule and Aragon cancelling TCT-30126.
 Emilia E. de Legare filed an action for annulment of the deeds of sales. The case reached the Court of
Appeals which ruled to revive TCT-21253 in favor of Emilia E. de Legare.

Issue: Whether the transfer of the properties in question to petitioners Fule and Aragon was valid.

Held: YES.

Ruling:

 As a rule, a forged or fraudulent deed is a nullity and conveys no title. However, a fraudulent document
may become the root of a valid when the same was already transferred from the name of the true owner
to the forger, and while it remained that way, the land was subsequently sold to an innocent purchaser.

In the present case, Although the deed of sale in favor of John W. Legare was fraudulent, the fact remains
that he was able to secure a registered title to the house and lot. It was this title which he subsequently
conveyed to the herein petitioners.

 Moreover, under the Torrens system, "registration is the operative act that gives validity to the transfer or
creates a lien upon the land (Secs. 50 and 51, Land Registration Act). Consequently, where there was
nothing in the certificate of title to indicate any cloud or vice in the ownership of the property, or any
encumbrance thereon, the purchaser is not required to explore farther than what the Torrens title upon its
face indicates in quest for any hidden defect or inchoate right that may subsequently defeat his right
thereto. If the rule were otherwise, the efficacy and conclusiveness of the certificate of title which the
Torrens system seeks to insure would entirely be futile and nugatory. (Reynes vs. Barrera, 68 Phil. 656; De
Lara and De Guzman vs. Ayroso, 50 O.G. No. 10, 4838). The public shall then be denied of its foremost
motivation for respecting and observing the Land Registration Act. In the end, the business community
stands to be inconvenienced and prejudiced immeasurably.

Thus, when the Register of Deeds issued a certificate of title in the name of John W. Legare, and thereafter
registered the same, John W. Legare, insofar as third parties were concerned, acquired a valid title to the
house and lot here disputed. When, therefore, he transferred this title to the herein petitioners, third
persons, the entire transaction fell within the purview of Article 1434 of the Civil Code. The registration in
John W. Legare's name effectively operated to convey the properties to him.

ART. 1434. When a person who is not the owner of a thing sells or alienates and delivers it, and
later the seller or grantor acquires title thereto, such title passes by operation of law to the buyer
or grantee.

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