Case Digest (G.R. No. 111357)
Facts:
In Central Realty and Development Corporation (“Central”) vs. Solar Resources, Inc. and the Register of Deeds of Manila (G.R. No. 229408, November 9, 2020), Central acquired a 7,350-sqm parcel in Binondo, Manila from the Philippine National Bank by Deed of Sale dated December 15, 1989, originally covered by OCT No. 10964, later reissued as TCT No. 198996. In May 2010, Dolores V. Molina had a notice of adverse claim annotated on TCT No. 198996, asserting she had purchased the property in 1993. Central denied any sale to Molina and, on February 4, 2011, filed before RTC-Manila Branch 4 a petition to cancel that adverse claim. While that petition was pending, Central entered into a joint venture with Federal Land, Inc. and secured HLURB permits in September 2011. Molina demanded title issuance in March 2012; upon non‐compliance, she sued Central and Federal Land for specific performance in September 2013 (RTC-Manila Branch 6). On December 18, 2013, Solar purchased Molina’s allegedCase Digest (G.R. No. 111357)
Facts:
- Property and Initial Sale
- The Philippine National Bank sold to Central Realty and Development Corporation (Central) by Deed of Sale dated December 15, 1989, a parcel in Binondo, Manila covered by OCT No. 10964 (7,350 sq m).
- OCT No. 10964 was cancelled and TCT No. 198996 was issued to Central.
- Central consistently exercised acts of ownership: tax payments, leasing portions, mortgaging, and entering into a September 23, 2011 joint venture with Federal Land, Inc. (Federal Land) for a condominium project (approved by HLURB).
- Adverse Claims and Competing Litigations
- May 2010 – Dolores V. Molina caused annotation of an adverse claim on TCT No. 198996, alleging a 1993 sale by Central.
- February 4, 2011 – Central filed Civil Case No. P-11-726/LRC N-86 for cancellation of Molina’s adverse claim (Branch 4, RTC-Manila). April 11, 2014 – Branch 4 ordered cancellation of Molina’s adverse claim, finding it baseless.
- September 10, 2013 – Molina filed Civil Case No. 13-130626 (Branch 6, RTC-Manila) for specific performance and nullity of mortgage against Central and Federal Land; docketed before Molina’s sale to Solar.
- December 18, 2013 – Solar Resources, Inc. (Solar) purchased the property from Molina and on June 9, 2014 annotated its own adverse claim on TCT No. 198996.
- Solar sought substitution in Civil Case No. 13-130626 after Molina’s death; CA later reversed substitution (CA-G.R. SP No. 151032, May 11, 2018).
- Central then filed Civil Case No. P-14-0163 (Branch 16, RTC-Manila) for cancellation of Solar’s adverse claim, alleging:
- Lapse of 30-day annotation period;
- Procedural defect – based on cancelled Molina claim;
- Baselessness – no valid title in Molina;
- Solar not an innocent purchaser, allegedly conspiring with Molina.
- Solar opposed, invoking litis pendentia (ownership issues in Branch 6 case), asserting good faith and distinct adverse claim.
- Central moved for judgment on the pleadings; Solar moved to dismiss for litis pendentia. Both motions remained pending.
- February 4, 2016 – Trial court (Branch 16) admitted judicial affidavits from both sides.
- May 30, 2016 – Trial court issued an omnibus resolution:
- Denied Central’s motion for judgment on the pleadings (Solar raised affirmative defenses).
- Denied Solar’s motion to dismiss for litis pendentia (no common cause of action).
- Rendered summary judgment motu proprio, sustaining Solar’s adverse claim (based on Solar–Molina deed) and dismissing Central’s petition.
- January 3, 2017 – Motion for partial reconsideration denied.
- Central filed a Rule 45 petition before the Supreme Court raising pure questions of law and seeking declaration of ownership and consolidation of all related cases.
Issues:
- Does the petition raise only questions of law, thereby justifying direct resort to the Supreme Court under Rule 45?
- What are the legal effects of the May 30, 2016 Omnibus Resolution on Central’s petition, Solar’s opposition with motion to dismiss, and Central’s motion for judgment on the pleadings?
- Can the Supreme Court in this Rule 45 proceeding declare Central as the lawful owner of the property?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)