Short and sweet...the homeowner is the victim. IF they are insured with an owners title insurance policy, they may be covered against a financial loss, but that sure doesn't make them feel any less victimized.
(And if you REALLY want a bit more info on the role played by title insurance, you might check out my replies on an earlier real-estate fraud thread:
5 Accused of Selling Dozens of Houses With Fake Deeds )