Sajonas vs. Court of Appeals
Sajonas vs. Court of Appeals
Sajonas vs. Court of Appeals
the claimed right together with other datas pertinent thereto. The
VOL. 258, JULY 5, 1996 79 registration of an adverse claim is expressly recognized under
Section 70 of P.D. No. 1529.
Sajonas vs. Court of Appeals
Same; Land Registration; Torrens System; Under the Torrens
* system, registration is the operative act which gives validity to the
G.R. No. 102377. July 5, 1996.
transfer or creates a lien upon the land.—Under the Torrens
system, registration is the operative act which gives validity to
ALFREDO SAJONAS and CONCHITA SAJONAS, the transfer or creates a lien upon the land. A person dealing with
petitioners, vs. THE COURT OF APPEALS, DOMINGO A. registered land is not required to go behind the register to
PILARES, SHERIFF ROBERTO GARCIA OF QUEZON determine the condition of the property. He is only charged with
CITY and REGISTER OF DEEDS OF MARIKINA, notice of the burdens on the property which are noted on the face
respondents. of the register or certificate of title.
Same; Same; Same; One who buys without checking the
Land Titles; Adverse Claims; Annotation of an adverse claim vendor’s title takes all the risks and losses consequent to such
is a measure designed to protect the interest of a person over a failure.—While it is true that under the provisions of the Property
piece of real property where the registration of such interest or Registration Decree, deeds of conveyance of property registered
right is not otherwise provided for by the Land Registration Act or under the system, or any interest therein only take effect as a
Act 496 (now P.D. 1529) and serves a warning to third parties conveyance to bind the land upon its registration, and that a
dealing with said property that someone is claiming an interest on purchaser is not required to explore further than what the
the same or a better right than that of the registered owner thereof. Torrens title, upon its face, indicates in quest for any hidden
—Concededly, annotation of an adverse claim is a measure defect or inchoate right that may subsequently defeat his right
designed to protect the interest of a person over a piece of real thereto, nonetheless, this rule is not absolute. Thus, one who buys
property where the registration of such interest or right is not from the registered owner need not have to look behind the
otherwise provided for by the Land Registration Act or Act 496 certificate of title, he is, nevertheless, bound by the liens and
(now P.D. 1529 or the Property Registration Decree), and serves a encumbrances annotated thereon. One who buys without checking
warning to third parties dealing with said property that someone the vendor’s title takes all the risks and losses consequent to such
is claiming an interest on the same or a better right than that of failure.
the registered owner thereof. Such notice is registered by filing a
Statutory Construction; Taken in solitude, a word or phrase
sworn statement with the Register of Deeds of the province where
might easily convey a meaning quite different from the one
the property is located, setting forth the basis of
actually intended and evident when a word or phrase is considered
with those with which it is associated.—In construing the law
______________________________ aforesaid, care should be taken that every part thereof be given
effect and a construction that could render a provision inoperative
* SECOND DIVISION. should be avoided, and inconsistent provisions should be
reconciled whenever possible as parts of a harmonious whole. For
taken in solitude, a word or phrase might easily convey a meaning
80 quite different from the one actually intended and evident when a
word or phrase is considered with those with which it is
associated. In ascertaining the period of effectivity of an (now P.D. 1529 or the Property Registration Decree), and serves
inscription of adverse claim, we must read the law in its entirety. as a warning to third parties dealing with said property that
someone is claiming an interest on the same or a better right than
81 the registered owner thereof.
Land Titles; Adverse Claims; Writs of Execution; A notice of
VOL. 258, JULY 5, 1996 81 levy cannot prevail over an existing adverse claim inscribed on the
certificate of title.—In sum, the disputed inscription of adverse
Sajonas vs. Court of Appeals claim
83