View full case

JOSEFINA V. NOBLEZA v. SHIRLEY B. NUEGA

FACTS:

This case involves a dispute between respondent Shirley B. Nuega and petitioner Josefina V. Nobleza over the ownership of a property. Respondent and Rogelio A. Nuega were married in 1990 and resided in the subject property, which was purchased by Rogelio in 1989. However, respondent later discovered that Rogelio was introducing another woman as his wife. Respondent then filed two cases against Rogelio in 1992, one for Concubinage and another for Legal Separation and Liquidation of Property. During this time, respondent cautioned interested buyers, including petitioner, against purchasing the subject property until the cases are resolved. Despite this, Rogelio sold the property to petitioner without respondent's consent.

The court granted respondent's petition for Legal Separation and ordered the dissolution and liquidation of the community property. Respondent then filed a Complaint for Rescission of Sale and Recovery of Property against petitioner and Rogelio. The trial court ruled in favor of respondent, ordering the rescission of the sale and reconveyance of the property. Petitioner appealed the decision to the Court of Appeals.

Rogelio did not appeal the ruling of the trial court. The appellate court affirmed with modification the trial court's ruling, declaring null and void the Deed of Absolute Sale dated 29 December 1992 and ordering the reconveyance of the subject property to Shirley B. Nuega and Rogelio Nuega. Petitioner moved for reconsideration but it was denied. Petitioner filed a petition with the court raising two errors.

Petitioner claims to be a buyer in good faith of the subject property, which is titled under the name of the seller Rogelio A. Nuega alone. Petitioner argues that she is not required to go beyond the face of the title in verifying the status of the subject property at the time of the sale. The court disagrees with petitioner, stating that a buyer cannot claim to be an innocent purchaser for value by merely relying on the Torrens title of the seller while ignoring other surrounding circumstances relevant to the sale. The court cited a previous case wherein the buyer was not considered an innocent purchaser for value due to relevant circumstances such as the buyer being a grandniece of the seller and residing in the same locality where the seller conducts business.

ISSUES:

  1. Whether the petitioner is an innocent purchaser for value.

  2. Whether the petitioner should have been put on guard regarding any defect in the title of the seller.

  3. Whether the Deed of Absolute Sale dated December 29, 1992 is valid.

  4. Whether the subject property forms part of the absolute community property of the spouses.

RULING:

  1. The petitioner is not an innocent purchaser for value. The court considered the surrounding circumstances and the petitioner's knowledge of the seller's business practices. It was determined that the petitioner should have been aware of possible abuses that the seller may commit with the titles and deeds of sale in her possession.

  2. The petitioner should have been put on guard regarding any defect in the title of the seller. The court emphasized that a buyer cannot claim to be an innocent purchaser for value merely by relying on the Torrens title of the seller and ignoring other relevant surrounding circumstances.

  3. The Deed of Absolute Sale dated December 29, 1992 is void in its entirety.

  4. The subject property forms part of the absolute community property of the spouses.

PRINCIPLES:

  • A buyer cannot claim to be an innocent purchaser for value by merely relying on the title of the seller and ignoring other relevant circumstances.

  • The law does not require a person dealing with registered land to inquire beyond what the Torrens Title shows on its face, but this rule is not absolute and a prudent buyer should take necessary precautions.

  • Surrounding circumstances and the buyer's knowledge of the seller's business practices may be considered in determining whether the buyer is an innocent purchaser for value.

  • Actual contribution is not relevant in determining whether a property is community property. The law itself defines what constitutes community property. (Article 91 of Family Code)

  • Properties acquired during the marriage (except those excluded under Article 92 of the Family Code) form the common mass of the couple's properties. Regardless of their respective contribution to its acquisition before their marriage or the names appearing in the title, the property is owned jointly by the spouses. (Quiao v. Quiao)

  • In case of the disposition of a communal property without the consent of the other spouse, the disposition is void. (Article 96 of Executive Order No. 209)

  • Under Article 124 of the Family Code, the disposition or encumbrance of conjugal property without the written consent of the other spouse or authority from the court is void.

  • If the husband, without knowledge and consent of the wife, sells the conjugal property, such sale is void.

  • The consent of both spouses is required for the disposition or encumbrance of conjugal property, and the absence of consent of one renders the entire sale null and void.

  • The absolute community of property is liable for debts and obligations contracted by either spouse without the consent of the other, to the extent that the family may have been benefited.