Tuesday, January 22, 2019

Case Digest: Heirs of Victorino Sarili v. Pedro Lagrosa G.R. No. 193517 January 15, 2014


Facts:
Respondent Pedro Lagrosa is the owner of a parcel of land situated in Caloocan City. He resided in California, USA and during a vacation in the Philippines found that a new certificate of title was issued by the RD in the name of Victorino Sarili by virtue of an alleged falsified document by Sps. Sarili and the RD. Sps. Sarili maintained that they are innocent buyers for value having purchased the property from Ramon B. Rodriguez who possessed and presented a Special Power of Attorney to sell/dispose the property.

Issue:
Whether or not there was a valid conveyance of the subject property to Sps. Sarili.

Ruling:
Since the notarization of the Special Power of Attorney was defective, the sale between Victorino and Ramon is void. Accordingly, the land title in the name of Victorino married to Isabel should be annulled and the name of respondent be reinstated. As to the house built by Sps. Sarili on the land, since he was aware of the palpable irregularity in the Special Power of Attorney and that the person he was dealing with was possibly not authorized, he is considered a builder in bad faith.

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