G.R. No. 163972-77 - Daan vs. Sandiganbayan

On December 29, 1964, Lot No. 4213-A, situated at Solano, Nueva Ecija, covered by TCT No. T-2679, was sold by its original owners, the spouses Apolonio Laconza and Felicitas Ordonez, to petitioners Petronila Bulan and Roberto Garcia.
The deed of sale was duly registered and annotated on the back of the certificate of title on January 4, 1965, under entry No. 73830.

A previous annotation of an adverse claim against the former owners (the spouses Apolonio Laconza and Felicitas Ordonez) was recorded.
The adverse claim, registered on December 3, 1964, under entry No. 73492, stated:

The claim consisted of the allegation that the parcel was given as collateral for an obligation amounting to TWO THOUSAND TWO HUNDRED TWENTY FIVE PESOS (P2,225.00) plus additional considerations amounting to FIVE THOUSAND PESOS (P5,000.00).
It was further asserted that the registered owners had refused, and continued to refuse, to execute the necessary deed because the property was mortgaged with the Development Bank of the Philippines, which held the certificate of title.

Petitioners contended that the adverse claim was defective since it was unsupported by a corresponding document, rendering it ineffective for binding a registered land.
They filed a petition for cancellation of the adverse claim under Section 110 of the Land Registration Act.
The adverse claimant opposed the petition, arguing that the annotation was proper and that petitioners should have availed themselves of the remedy provided by Article 476 of the Civil Code regarding the quieting of title.
The lower court, on February 26, 1965, sustained the adverse claimant’s position and dismissed the petition.

Petitioners, after a denied motion for reconsideration, elevated the matter to the Supreme Court via a petition for certiorari and mandamus.
They sought to set aside the lower court’s order and compel the respondent Judge to determine the validity of González I. Guevara’s adverse claim pursuant to Section 110 of Act 496.

Whether petitioners, having purchased the property subject to the adverse claim, were the proper parties to seek its cancellation.
Whether the previous owners, against whom the adverse claim was originally filed, should be included as indispensable parties in the proceedings.

Whether the petition for cancellation under Section 110 of the Land Registration Act is the proper remedy in a case involving a registered adverse claim that is principally directed against the previous owners.
Whether petitioners should have instead availed themselves of the remedy of quieting of title as provided by Article 476 of the Civil Code.

Whether the petition for certiorari and mandamus is the proper recourse given that the lower court’s dismissal did not involve jurisdictional excess or grave abuse of discretion.
Whether an ordinary appeal would have been a more appropriate remedy for any alleged error of judgment by the lower court.