Land buyers must check title, registry records -SC

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

In a decision by its Third Division, the SC voided the land titles of a married couple after finding they failed to conduct due diligence when purchasing two properties.

“Thus, if the register contains a registered instrument which indicates a flaw or defect in the title or right of the person who that someone is transacting with, or a right or interest in the registered property of some other person, the claim of good faith by that someone, whether he or she inquired into the register, cannot be sustained,” the SC stated.

Conversely, the Court noted that if no such instrument is registered, a buyer’s good faith remains intact even without further inquiry.

The case involved a couple who bought two parcels of land from a woman who fraudulently acquired her titles. She presented certificates of title in her name and a deed of sale as proof of ownership, claiming she had purchased the properties from the original owners.

However, the estate’s administrator contested the validity of the titles before the Regional Trial Court (RTC). 

The couple argued they were innocent buyers, but both the RTC and the Court of Appeals (CA) ruled otherwise, citing their failure to investigate the property's ownership history despite red flags.

The SC upheld these rulings, emphasizing that “since petitioners did not inquire into the register, and even without such inquiry, they are nonetheless constructively notified of every registration affecting the said subject properties, they cannot feign ignorance of such registrations.”

The decision, penned by Associate Justice Alfredo Benjamin Caguioa, was promulgated in November 2024 and made public in March 2025. — DVM, GMA Integrated News