G.R. No. L-42956-57 - A. Doronila Resources Development, Inc. vs. Court of Appeals

Blue Chips Projects, Inc. is the registered owner of a parcel of land covering approximately 1,256,269 square meters, located in Bario Patiis, Municipality of San Mateo, Province of Rizal.
The property is evidenced by Transfer Certificate of Title (TCT) No. 344936, registered with the Registry of Deeds of Rizal.
Blue Chips Projects, Inc. acquired the property from Purita Landicho, who was the lawful registered owner under TCT No. 167681.

On December 11, 1972, petitioner A. Doronila Resources Dev., Inc. availed itself of the remedy of lis pendens by filing in Civil Case No. 12044 before the First Court of Instance of Rizal.
The lis pendens was duly annotated on TCT No. 344936, marking the commencement of a judicial proceeding to protect the petitioner’s claim.

On August 8, 1973, petitioner, through its President Alfonso Doronila, filed an affidavit of adverse claim for registration on TCT No. 344936.
The adverse claim asserted that the property covered by the title was part of a larger parcel purchased by the petitioner from Alfonso Doronila.
The Register of Deeds of Rizal denied the registration on the ground that the earlier anotated lis pendens adequately protected the petitioner’s rights and that an adverse claim was redundant.

Petitioner elevated the matter en consulta to the LRC, leading to LRC Consulta No. 887 where it was resolved on November 6, 1973, that the affidavit of adverse claim be denied registration.
Subsequently, on November 5, 1973, TCT No. 344936 was cancelled and substituted with TCT No. 425582, issued in favor of Winmar Poultry Farms Inc., with an annotation indicating that the property was subject to the resolution of LRC Consulta No. 887.

Not deterred, petitioner again applied for the registration of an affidavit of adverse claim identical to the previously filed one, this time referencing TCT No. 425582.
The Register of Deeds referred the matter back to the LRC for resolution under Section 4 of R.A. No. 1151, culminating in LRC Consulta No. 894 on January 8, 1974, where the registration was again denied.
Petitioner appealed these adverse resolutions by consolidating cases (SP-02569 and SP-02711) and filed a petition before this Honorable Court on March 12, 1974.

On November 26, 1975, the Court of Appeals rendered a decision affirming the resolutions of the LRC in both Consulta Nos. 887 and 894.
The appellate decision held that since petitioner had already secured annotation of a lis pendens on TCT No. 344936, the subsequent registration of an adverse claim was redundant and unnecessary.

Whether the prior annotation of a notice of lis pendens on the certificate of title (and its successor) precludes the registration of an affidavit of adverse claim.
Whether the petitioner’s right to register an adverse claim is valid and should be recognized independently of the earlier lis pendens, given that both instruments serve as notices of an asserted interest.
Whether it is appropriate to hold that the filing of a civil action (resulting in a lis pendens) automatically nullifies the necessity or validity of registering an adverse claim, considering that both are intended to offer protection and public notice of a claimant’s rights.