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Question
(a) Identify the Operative Fact Doctrine and state the controlling rule governing acts performed under a repealed or amended land-registration law.
(b) Apply the doctrine to the following facts: On March 15, 2001, L executed a deed of absolute sale of a parcel of land to M under the Land Registration Act then in force. Possession was delivered to M on March 20, 2001, and a Transfer Certificate of Title was issued in M’s name on April 5, 2001. On September 1, 2008, the statute was repealed and replaced by a new Land Registration Law. In 2016, N challenges M’s title as void due to repeal. Decide whether M’s title remains valid or not under the Operative Fact Doctrine, and explain the effect on N’s claim.