A Void Title May Become the Root of a Valid Title in the Hnads of An Innocent Holder for Value

The Supreme Court in the case of Fule vs. De Legare, 7 SCRA 351, (1963) held:

" We have indeed ruled that a forged or fraudulent deed is a nullity and conveys no title (Director of Lands vs. Addison, 49 Phil. 19). However, we have also laid down the doctrine that there are instances when such fraudulent document may become the root of valid title. One such instance is where the certificate of title was laready transferred from the name of the true owner to the forger,and while it remained that way, the land was subsequently sold to an innocent purchaser.For then, the vendee had the right to rely upon what appeared in the certificate (Inquimbos vs. Cruz, G.R. No. L-13953, July 28, 1960).