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FACTS: During the marriage of the Rufloes, they acquired the land in question. Respondent forged the
signatures of the spouses in a Deed of Sale. Because of this, she succeeded in obtaining a certificate of
title in her name. The Rufloes then filed a complaint against De los Reyes . During the pendency of the
case, De los Reyes sold the property to respondent Burgos siblings which was later sold to their aunt

Since the sale in favor of the aunt was not registered, no title was issued in her name.

The RTC ruled in favor of Rufloe saying that the Deed of Sale was falsified because of the forged
signatures. Rufloes then filed a complaint for Declaration of Nullity of Contract and Cancellation of
Transfer Certificate of Titles against the respondents. Alleging that since Deed of Sale was falsified, then
no valid title was ever given to the Burgos siblings.


(1) W/N the sale of the parcel of land by Delos Reyes to the respondents were valid and binding

RULING: NO . Since the Deed of Sale executed by De los Reyes in favor of the Burgos siblings and the
subsequent sale to their aunt was simulated based on forged signatures, no certificate of title was ever
issued in their name. Thus, it is a well-settled principle that no one can give what one does not have.
One can sell only what one owns or is authorized to sell, and the buyer can acquire no more right than
what the seller can transfer legally. The respondents could not be considered buyers in good faith.

Sandoval vs CA

FACTS: The subject property is a parcel of land issued in the name of private respondent, Tan. He
discovered that the adverse claim of one Godofredo Valmeo had been annotated on his title. Apparently,
an impostor, mortgaged the property to Valmeo to secure a loan. Thereafter, the real Tan sued for the
cancellation of the annotation of mortgage and damages against Almeda and Valmeo.

Tan alleged that petitioner had prior knowledge of the legal flaws, which tainted Almeda’s title.
Petitioner countered that he was a purchaser in good faith and for valuable consideration.

ISSUE: W/N petitioner Sandoval is a purchaser in good faith, hence, shouldn’t be held accountable for
the fraud committed against respondent Tan.

RULING: NO, he wasn’t. It is true that a forged deed can be the basis of a valid title, but only if the
certificate of title has already been transferred from the true owner’s name indicated by the forger and
while it remained as such, the land was subsequently sold to an innocent purchaser. a person dealing
with registered land has a right to rely on the Torrens certificate and dispense with the need of inquiring
further except when the party has actual knowledge of facts and circumstances that would impel a
reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the
lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the
status of the title of the property in litigation.