View full case

JOSEPH L. SY v. NICOLAS CAPISTRANO

FACTS:

The petitioner, Nicolas Capistrano, Jr., filed an action for reconveyance of a large tract of land in Caloocan City against several defendants. Capistrano alleged that he had been given temporary authority to sell the land by Nenita Scott in 1980, but later discovered that his Transfer Certificate of Title (TCT) had been cancelled and replaced with new TCTs issued to the Jamilar spouses, Golpeo, and Tan. Capistrano found irregularities in the transactions, such as discrepancies in the execution date of the deed of sale and the annotation on the TCT, and the lack of a direct sale from him to the Jamilars. The issuance of the new TCT in Jamilar's name was facilitated by Joseph Sy, who provided financial assistance for the payment of taxes and fees. Moreover, an Affidavit of Adverse Claim was annotated on Jamilar's TCT at the instance of Sy, Golpeo, and Tan, and TCT No. 249959 was later cancelled and replaced with three new TCTs in Jamilar's name under an alleged subdivision plan without Capistrano's knowledge and consent. Additionally, a civil case was filed by Sy, Golpeo, and Tan against the Jamilars and another couple, resulting in the execution of a Deed of Absolute Sale among the parties involved. Capistrano then filed an action for reconveyance, alleging forgery, possession of the owner's duplicate copy of the TCT, and fraudulent participation of the defendants. The trial court rendered a decision in favor of Capistrano after a trial on the merits.

ISSUES:

  1. Whether the Court of Appeals erred in affirming the trial court's decision declaring the sale of the property from Capistrano to Scott as a forgery.

  2. Whether the Court of Appeals erred in affirming the trial court's decision ordering the cancellation of TCT Nos. 262286 and 262287 registered in the names of petitioners.

  3. Whether the handwriting expert's technical procedure is necessary for examining or comparing handwritings.

  4. Whether the Jamilar spouses, the Gilturas, and Sy are innocent purchasers for value of the subject property.

RULING:

  1. The Court of Appeals did not err in affirming the trial court's decision declaring the sale of the property from Capistrano to Scott as a forgery. The findings of fact of the trial court and the Court of Appeals, which are final and conclusive unless shown to be based on speculations, surmises, or conjectures, support the conclusion that the sale was indeed a forgery.

  2. The Court of Appeals did not err in affirming the trial court's decision ordering the cancellation of TCT Nos. 262286 and 262287 registered in the names of petitioners. The trial court correctly found that petitioners were not innocent purchasers for value as they failed to exercise due diligence in investigating the validity of the title. They should have been put on guard by the suspicious circumstances surrounding the sale, such as the unregistered deed of sale, the long period of time it remained unregistered, and the low purchase price.

  3. The technical procedure of handwriting experts is not mandatory or indispensable for examining or comparing handwritings.

  4. The Jamilar spouses, the Gilturas, and Sy are not innocent purchasers for value of the subject property.

PRINCIPLES:

  • Findings of fact of the trial court and the Court of Appeals are final and conclusive on appeal, as long as they are based on substantial evidence, and will not be reviewed unless any of the exceptional circumstances are present.

  • A party claiming to be an innocent purchaser for value must exercise due diligence in investigating the validity of the title, and failure to do so will result in the loss of the status of an innocent purchaser for value.

  • The technical procedure of handwriting experts is not mandatory or indispensable for examining or comparing handwritings.

  • A person who deals with registered land through someone who is not the registered owner is expected to look beyond the certificate of title and examine all the factual circumstances thereof in order to determine if the vendor has the capacity to transfer any interest in the land.

  • A good faith buyer should at least see the owner's duplicate copy of the title.

  • In order to be considered an innocent purchaser for value, a party must have bought the property without any notice or knowledge of any defect or flaw in the title of the seller.