Rogelio Dizon v. Philippine · G.R. 165938

Petitioner: Rogelio Dizon
Respondent: Philippine Veterans Bank
Citation: G.R. No. 165938
Court: Supreme Court
Division: Third Division
Ponente: Peralta, J.
Decided: November 25, 2009

Summary

The Supreme Court denied Rogelio Dizon's petition challenging Philippine Veterans Bank's (PVB) right to obtain duplicate certificates of title over three foreclosed properties in Angeles City, Pampanga. After the Spouses Dizon defaulted on their mortgage obligations, PVB foreclosed the properties and acquired them at public auction in 1983. When PVB petitioned for duplicate titles in 1999 due to lost originals, Dizon opposed on grounds of prescription and authenticity. The Court held that prescription under Article 1142 of the Civil Code does not apply since PVB's petition arose from ownership rights, not mortgage rights. PD 1529 provides no prescriptive period for such petitions. Dizon was estopped from questioning the authenticity of titles he originally submitted to secure the loan. The decision affirmed PVB's valid ownership and right to obtain duplicate certificates, demonstrating the finality of foreclosure proceedings and the protection of subsequent purchaser rights in property law.

Statutes applied

Civil Code, Art. 1142

Related cases

Other Philippine cases on the same provisions and issues.

Irene Benedicto v. Court of Appeals G.R. No. 81344
Maxima P. Saclolo v. Romeo Marquito G.R. No. 229243
Development Bank of the Philippines v. Spouses Rufo Tomeldan G.R. No. 51269
Spouses Flavio P. Bautista v. Premiere Development Bank G.R. No. 201881
B & I Realty Co. v. Teodoro Caspe G.R. No. 146972
Valentina A. Nuñez v. Gsis Family Bank (Formerly Comsavings Bank) G.R. No. 163988
Sps. Salustiano Oca v. Court of Appeals G.R. No. 84841
Sheriff Albert A. Dela Cruz of the Sandiganbayan Security v. Wellex Group G.R. No. 247439

By the Intellegal Editorial Board · November 25, 2009

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