CARLOS MAÑACOP, JR., PLAINTIFF AND APPELLANT, VS. FAUSTINO CANSINO, DEFENDANT AND APPELLEE.

Mañacop versus Cansino

The Case

This is an action to recover possession of a parcel of land and damages, brought by Carlos Mañacop, Junior against Faustino Cansino. Mañacop claims ownership under a transfer certificate of title issued to him in 1956, while Cansino claims the same land by purchase from the original owner and by long, open possession. The case matters because it teaches what it takes to be a purchaser in good faith — and what happens to a registered title in the hands of one who buys with his eyes open to another's possession.

Procedural History

Mañacop sued Cansino in the Court of First Instance. After hearing, the trial court ruled for Cansino: it declared that Cansino and his predecessor had possessed the land since the dates of their purchases from Sabina Tomas, held Cansino's title superior, and ordered Mañacop's certificate of title nullified and cancelled. Mañacop appealed directly to the Supreme Court, raising only questions of law.

Facts

The land, in Cuyapo, Nueva Ecija, was originally covered by a homestead patent in the name of Sabina Tomas, and a certificate of title was issued to her in 1914. She later sold portions of it: to the Anchetas in 1920 and 1922, and to the Cansinos in 1922 and 1923. In the cadastral proceedings, Lot 342 was adjudicated to the Anchetas and Lot 387 to the Cansinos, each receiving their own certificates of title in 1925. In 1937 the Anchetas sold Lot 342 to the Cansinos, who consolidated both lots under a transfer certificate of title in 1938.

Meanwhile, Sabina Tomas's original title had been cancelled and replaced by a transfer certificate of title in her name in 1916. After she died in 1952, her children, Juliana and Clodualdo Dagdag, secured a second owner's duplicate of that title in 1953, executed an extrajudicial partition in their favor, and obtained a new title. In 1955 they sold the land to Benito Bringas, and in 1956 Bringas assigned it to Mañacop, who obtained his own transfer certificate of title.

In 1957 Mañacop sued to recover possession. Cansino answered that the land was his by purchase from Sabina Tomas and by more than thirty years of continuous, peaceful and exclusive possession. The trial court agreed with Cansino and cancelled Mañacop's title.

Issues

• Whether or not the two-year period in section 4 of Rule 74 applies to an extrajudicial settlement, so that the heirs' claims are barred after two years.
• Whether or not Mañacop is a purchaser in good faith, given that the land was openly in Cansino's possession when he bought it.

Applicable Provisions

Section 4 of Rule 74 of the Rules of Court, which the trial court applied and the plaintiff attacked, provides:

If it is made to appear at any time within two years after the settlement and distribution of an estate in accordance with the provisions of either of the two preceding sections, that an heir or other person has been unduly deprived of his lawful participation in the estate, such heir or person may compel the settlement of said estate in the court for the purpose of satisfying such lawful participation.

This provision fixes the period within which a person unduly deprived of his share may claim it after a summary settlement, and the trial court held that it does not apply where the settlement is extrajudicial.

Ruling

On the first issue, the Court found it unnecessary to decide whether the two-year period applies to extrajudicial settlements. It chose instead to rest its ruling on a ground that did not require resolving that question.

On the second issue, the Court held that Mañacop was not a purchaser in good faith. About nine months before buying, he went to the land and found it in Cansino's possession — openly, publicly, peacefully, continuously and adversely to the whole world, and so for many years. He was even told by one Abon that he could not cultivate the land because Cansino was cultivating it, and Bringas did not deny this. The Court ruled that one who is aware of sufficient facts to induce a reasonably prudent man to inquire into the status of the title cannot legally claim the rights of a purchaser in good faith. It added that, by appealing directly to the Supreme Court, Mañacop waived the right to question the trial court's finding that he was not such a purchaser.

Doctrine

A buyer of registered land who knows that another person is in open, continuous and adverse possession of it is charged with notice of that possessor's claim. He is not a purchaser in good faith, and his certificate of title cannot prevail over the title of the long-time possessor. Good faith requires inquiry, and one who closes his eyes to facts that would prompt a prudent man to investigate buys at his peril.

Disposition

The Supreme Court affirmed the decision of the trial court, with costs against Mañacop. Cansino won.

Remember This

Memorize the rule: open and adverse possession by another is a fact that defeats a buyer's claim of good faith. Examiners use this case to test purchaser-in-good-faith questions and the effect of notice arising from possession.