Eduarte v. Court of Appeals

Summary

Pedro Calapine donated property to his niece Helen Doria through two deeds in 1984. When Helen later sold the property to the Eduarte spouses for P110,000, Pedro sued claiming the second deed was forged, constituting ingratitude warranting revocation. The trial court and Court of Appeals found the signature was indeed forged based on NBI expert testimony and declared the Eduarte spouses as buyers in bad faith, nullifying their title. However, the Supreme Court reversed, holding that while the forgery constituted ingratitude under Article 765 of the Civil Code warranting donation revocation, the Eduarte spouses were innocent purchasers for value entitled to protection under the Torrens System. The Court applied the doctrine that forged deeds can become the root of valid title when property is sold to innocent purchasers who rely on apparently valid certificates of title. Helen Doria was ordered to pay damages to the original owner's heirs instead.