Tiburcio Samonte v. Court of Appeals

Summary

This case involves a property dispute over Lot No. 216 in Nasipit, Agusan del Norte, originally registered to Apolonia Abao and Irenea Tolero. After their deaths, Ignacio Atupan fraudulently claimed to be Abao's sole heir and caused the cancellation of the original title, facilitating the transfer of portions to Nicolas Jadol and subsequently to petitioner Tiburcio Samonte. The rightful heirs filed suit in 1975 seeking reconveyance. The Supreme Court affirmed lower court decisions favoring the heirs, applying the Adille doctrine that prescription runs from actual discovery of fraud rather than registration date. The Court ruled that Samonte was not a purchaser in good faith, having knowledge of the heirs' claims, and that fraudulent registration creates an implied trust under Article 1456 of the Civil Code. The decision reinforces the principle that Torrens titles obtained through fraud do not provide protection to bad faith transferees.