Gloria R. Cruz v. Court of Appeals

Summary

Gloria Cruz sold property to her common-law husband Romeo Suzara in 1982 without monetary consideration, solely out of love and affection. When their relationship ended, she sought to nullify the sale and recover the property. However, Suzara had already sold the property to Manuel Vizconde in December 1989, before Cruz filed her adverse claim in January 1990. The Supreme Court denied Cruz's petition, ruling that although sales between common-law spouses may be prohibited under Art. 1490 of the Civil Code, Vizconde was protected as a purchaser for value in good faith under the Torrens system. The Court emphasized that the Torrens system aims to protect innocent purchasers who rely on clean certificates of title, and Cruz's remedy, if any, should be pursued against Suzara rather than affecting Vizconde's indefeasible title.