Doctrine of Innocent Purchaser

Today, the Supreme Court is set to hear the oral arguments of the petition involving the Hacienda Luisita dispute. Petitioners, who are also President Benigno Aquino III’s cousins, are seeking to overturn a 2005 decision by the Presidential Agrarian Reform Council (PARC) scratching the stock distribution option (SDO) under CARP reached in 1989.

One of the issues to be discussed is whether the Luisita Industrial Park Corp. and Rizal Commercial Banking Corp., as transferees of a portion of the 6,500-hectare estate, may invoke the “doctrine of innocent purchaser.”

Now, what is exactly the doctrine of innocent purchaser?

The subject is summarily discussed in the case of Tan v. Dela Vega, G.R. No. 168809, 10 July 2006.

Accordingly, the doctrine of innocent purchaser rules that a void title may be the source of a valid title in the hands of an innocent purchaser for value. An innocent purchaser for value is one who buys the property of another, without notice that some other person has a right to, or interest in, such property and pays a full and fair price for the same at the time of such purchase, or before he has notice of the claims or interest of some other person in the property.