Mirror Doctrine for Buyers of Real Property

Mirror Doctrine echoes the doctrinal rule that every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and is in no way obliged to go beyond the certificate to determine the condition of the property. (Rufloe v. Burgos, G.R. No. 143573, January 30, 2009) The recognized exceptions to this rule are stated as follows:

A person dealing with registered land has a right to rely on the Torrens certificate of title and to 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. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor appearing on the face of said certificate. One who falls within the exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith and, hence, does not merit the protection of the law. (Sandoval v. Court of Appeals, G.R. No. 106657, August 1, 1996)

Thus, in Domingo Realty, Inc. v. CA (G.R. No. 126236, January 26, 2007), we emphasized the need for prospective parties to a contract involving titled lands to exercise the diligence of a reasonably prudent person in ensuring the legality of the title, and the accuracy of the metes and bounds of the lot embraced therein, by undertaking precautionary measures, such as:

  1. Verifying the origin, history, authenticity, and validity of the title with the Office of the Register of Deeds and the Land Registration Authority;
  2. Engaging the services of a competent and reliable geodetic engineer to verify the boundary,metes, and bounds of the lot subject of said title based on the technical description in the said title and the approved survey plan in the Land Management Bureau;
  3. Conducting an actual ocular inspection of the lot;
  4. Inquiring from the owners and possessors of adjoining lots with respect to the true and legal ownership of the lot in question;
  5. Putting up of signs that said lot is being purchased, leased, or encumbered; and
  6. Undertaking such other measures to make the general public aware that said lot will be subject to alienation, lease, or encumbrance by the parties.

Read: Locsin vs. Hizon (GR. No. 204369, September 17, 2014)

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