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Martinez Vs CA

This case involved a dispute over ownership of two parcels of land in Lubao, Pampanga between spouses Romeo Martinez and Leonor Suarez and the Secretary of Public Works and Communications. The spouses claimed they purchased the properties, including the disputed second parcel, in good faith. However, the Supreme Court ruled they could not be considered purchasers in good faith, as the deed made clear there were obstacles to converting the second parcel into a fishpond, and they willfully assumed the risks of purchasing land with a defective title. The land was determined to be a public river not subject to private ownership.

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547 views1 page

Martinez Vs CA

This case involved a dispute over ownership of two parcels of land in Lubao, Pampanga between spouses Romeo Martinez and Leonor Suarez and the Secretary of Public Works and Communications. The spouses claimed they purchased the properties, including the disputed second parcel, in good faith. However, the Supreme Court ruled they could not be considered purchasers in good faith, as the deed made clear there were obstacles to converting the second parcel into a fishpond, and they willfully assumed the risks of purchasing land with a defective title. The land was determined to be a public river not subject to private ownership.

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Martinez vs CA (56 SCRA 647) GR No.

L- 31271, April 29 1974

Facts:

The spouses Romeo Martinez and Leonor Suarez are the registered owners of two (2) parcels of land located in Lubao,
Pampanga. The disputed property was originally owned by one Paulino Montemayor, who secured a "titulo real" over it
way back in 1883. After the death of Paulino Montemayor the said property passed to his successors-in-interest, Maria
Montemayor and Donata Montemayor, who in turn, sold it, as well as the first parcel, to a certain Potenciano Garcia.

Because Potenciano Garcia was prevented by the then municipal president of Lubao, Pedro Beltran, from restoring the
dikes constructed on the contested property, Garcia filed a civil case with the Court of First Instance against Beltran to
restrain the latter in his official capacity from molesting him in the possession of said second parcel, and on even date,
applied for a writ of preliminary injunction, which was issued against said municipal president. The Court declared
permanent the preliminary injunction.

On April 17, 1925. Potenciano Garcia applied for the registration of both parcels of land in his name, and the Court of
First Instance of Pampanga, sitting as land registration court, granted the registration.

Thereafter, the ownership of these properties changed hands until eventually they were acquired by the spouses.

To avoid any untoward incident, the disputants agreed to refer the matter to the Committee on Rivers and Streams,
which, after conducting an ocular inspection, reported that the parcel was not a public river but a private fishpond
owned by the herein spouses.

The Secretary of Public Works and Communications, ordered another investigation of the said parcel of land, directing
the spouses to remove the dikes they had constructed, threatening that the dikes would be demolished should the
spouses fail to comply therewith within 30 days.

Issue: Whether the spouses are purchasers for value and in good faith on the parcel alleged to be a public river.

Held: No, they are not.

There is no weight in the spouses' argument that, being a purchaser for value and in good faith of Lot No. 2, the
nullification of its registration would be contrary to the law and to the applicable decisions of the Supreme Court as it
would destroy the stability of the title which is the core of the system of registration. Appellants cannot be deemed
purchasers for value and in good faith as in the deed of absolute conveyance executed in their favor.

Before purchasing a parcel of land, it cannot be contended that the spouses did not know exactly the condition of the
land that they were buying and the obstacles or restrictions thereon that may be put up by the government in
connection with their project of converting Lot No. 2 in question into a fishpond. Nevertheless, they willfully and
voluntarily assumed the risks attendant to the sale of said lot. One who buys something with knowledge of defect or lack
of title in his vendor cannot claim that he acquired it in good faith.

The ruling that a purchaser of a registered property cannot go beyond the record to make inquiries as to the legality of
the title of the registered owner, but may rely on the registry to determine if there is no lien or encumbrances over the
same, cannot be availed of as against the law and the accepted principle that rivers are parts of the public domain for
public use and not capable of private appropriation or acquisition by prescription.

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