32. Juan Sandoval et al vs CA GR No.

106657 August 1, 1996 ROMEO, J: FACTS: An impostor succeeded in selling property lawfully titled in anothers name by misrepresenting himself as the latter. The subject property is a parcel of land on which a five-door apartment building stands. It is covered by TCT No. 196518 in the name of Lorenzo L. Tan, Jr. married to Carolina Mangampo and located at No. 88 Halcon Street, Quezon City. Lorenzo L. Tan, Jr. was notified of the need to present his owners copy of the TCT to the Registry of Deeds but he explained that he was still looking for his copy of the TCT. Later, he discovered that the adverse claim of one Godofredo Valmeo had been annotated on his title in the Registry of Deeds. A Lorenzo L. Tan, Jr., an impostor, had mortgaged the property to Valmeo on October 9, 1984 to secure a P70,000.00 obligation. On December 6, 1984, the real Lorenzo L. Tan, Jr., filed a complaint for cancellation of the annotation of mortgage and damages against Bienvenido Almeda and Godofredo Valmeo before the RTC of Quezon City. TCT No. 196518 in the name of Lorenzo L. Tan, Jr. was cancelled and a new one, TCT No. 326781, was issued in the name of Bienvenido Almeda. Bienvenido Almeda sold the subject property to petitioner Juan C. Sandoval for P230,000.00. TCT No. 326781 was cancelled and TCT No. 329487 was issued in favor of Juan C. Sandoval on April 18, 1985. Private respondent alleged that petitioner had prior knowledge of legal flaws which tainted Bienvenido Almedas title but petitioner countered that he was a purchaser in good faith and for valuable consideration. ISSUE: WON petitioner Juan Sandoval is a purchaser in good faith HELD: No. A finding that petitioner is a purchaser in good faith will inevitably be followed by a declaration that, as such, he is the rightful owner of the property in question. For even granting, as held by both the trial and respondent appellate courts, that the deed of sale from the fake Lorenzo L. Tan, Jr. to Bienvenido Almeda is a forged instrument which, being a nullity, conveys no title still a forged deed can be the basis of a valid title. The Court has held that a fraudulent or forged document of sale may give rise to a valid title if the certificate of title has already been transferred from the name of the true owner to the name indicated by the forger and while it remained as such, the land was subsequently sold to an innocent purchaser. Unquestionably, the vendee had the right to rely upon the certificate of title. It is settled doctrine that one who deals with property registered under the Torrens system need not go beyond the same, but only has to rely on the title. He is charged with notice only of such burdens and claims as are annotated on the title. The aforesaid principle admits of an unchallenged exception: that a person dealing with registered land has a right to rely on the Torrens certificate of title and to dispense with the need of inquiring further except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor appearing on the face of said certificate. One who falls within the exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith; and hence does not merit the protection of the law.

52. Lawrence Bowe vs Court of Appeals GR No. 95771 March 19, 1993 CAMPOS, JR. J: FACTS: Teodoro Garcia's wife Luz Garcia was the owner of a 2 storey, 6-door apartment in Olongapo City. She entered into a contract of lease with Laura Arbolario over the same property. Teodoro Garcia and his son, Serafin Garcia, verbally agreed to sell subj house and lot to the Arbolario spouses for P220k. After had already made several payments, Garcia wrote them a letter that the deal is off . Later, Serafin went to Arbolarios and offered an accounting of the amounts they have paid (to compute them as rentals) but Arbolarios refused claiming that the house and lot was already their property this was done when the contract of lease was over. Garcias filed a complaint against Arbolarios before the RTC of Olongapo alleging that: conditions on contract of lease have been fully satisfied and also asked for various damages. There was a prayer for termination of the contract of lease as of September 1, 1984 and to reimburse all rents received from said 6-door apartment from September 2, 1984 up to the time she shall vacate the premises. Arbolarios add that they already made considerable improvements and repairs on the apartments and that they have a perfect right not to vacate the premises being owners thereof by virtue of the sale they also expressed willingness to tender remaining balance P153K upon order of the court. ISSUE: WON the contract of lease has been supplanted or abandoned? HELD: No the contract of lease has not been supplanted or abandoned because of lack of notice to vacate. An implied new lease or tacita reconduccion will set in if it is shown that: (a) the term of the original contract of lease has expired; (b) the lessor has not given the lessee a notice to vacate; and (c) the lessee continued enjoying the thing leased for fifteen days with the acquiescence of the lessor. This acquiescence may be inferred from this failure to serve a notice to quit. Discontinuance of lease must be AN EXPRESS NOTICE TO VACATE made within 15 day period. In this case, implied renewal of the lease contract hence no unlawful detainer. No talks have been held concerning the renewal of the lease. Not only was there an absence of notice to vacate but there were also no communications that transpired between the parties regarding the lease. The earliest communication that has been shown was in October, 1984, definitely way beyond the 15-day statutory period required by law.

7. FRANCISCO F. BAYLOSIS vs PEOPLE OF THE PHILIPPINES GR NO. 152119 August 14, 2007 Velasco, JR, J: FACTS: An Information was filed against petitioner Baylosis for the crime of estafa before the Cebu City Regional Trial Court. During arraignment, a plea of NOT GUILTY was entered. Trial ensued in absentia as the accused, being out on bail, did not appear during trial. The prosecution presented two witnesses, namely: (1) Ricardo Tabasa, Warehouse Operations Manager of Pepsi Cola Products Philippines, Inc. (PCPPI); and (2) Leopoldo Abella, PCPPIs Route Manager. Soon after the confession made by petitioner, a cash count and physical inventory were conducted in the presence of two witnesses. It turned out that the shortage was in the total amount of PhP 118,181.71, which covered the cash sales collection and the physical inventory. These results were all contained in cash count and physical inventory sheets which the accused acknowledged and signed, and even added the notation that the money was used to put to special projects for following-up of land title. A demand was made on petitioner to produce the deficient amount but failed to return it, thus, resulting in his preventive suspension and the conduct of an administrative investigation against him. The investigation was rescheduled to several dates due to his non-appearance despite notice. He was dismissed from service as a result of the investigation and based on the documentary evidence that were submitted, and was served a notice of termination. Prosecution witness Abellas testimony merely corroborated Tabasas testimony where he stated that petitioner voluntarily signed the cash count sheet and further claimed that petitioner voluntarily admitted to the misappropriation. Petitioner having jumped bail and his counsel manifesting to the court to have the case submitted for decision resulted in petitioners waiver of the right to submit evidence. ISSUE: Whether the CA acted with grave abuse of discretion in denying his Motion for New Trial filed under Section 14, Rule 124 of the 2000 Rules of Criminal Procedure, as it amounted to a disregard of the doctrine laid down by this Court in Jose v. Court of Appeals HELD: The CA, in denying petitioners motion, observed the fact that the lone affidavit dealt with statements made by Aya -ay, PCPPIs Credit and Collection Manager, regarding the payments made by petitioner of the amounts that he borrowed after the trial cour t promulgated its January 10, 1992 judgment. Such testimony, however, does not qualify as newly discovered evidence as a ground for a motion for new trial. Further, petitioner cites Jose in support of his cause and argues that he does not rely on newly discovered evidence but instead on substantial justice bolstered by Sec. 11, Rule 124 of the Rules of Court. The existence of said documents was however unrevealed during the trial of his case so as to protect the identity of petitioner Jose as an undercover agent of the Philippine Constabulary. And it was only when he was convicted that the competent authorities then reali zed that it was unjust for this man to go to jail for a crime he had not committed, hence, came the desired evidence concerning petitioners appointment x x x.