CHAIN OF TITLE DOCTRINE 2.0: A Critical Analysis of Plana v. Tan Chua on the Rights of a Defrauded Owner vis-à-vis an Innocent Purchaser/Mortgagee for Value

In the recent en banc case of Plana v. Tan Chua, the Supreme Court had the occasion to tackle the application of the mirror doctrine regarding registered land.  Under that doctrine as codified in Section 44 of the Property Registration Decree, a purchaser of registered land taking a certificate of title for value and in…