G.R. No. L-27594 - Director of Lands vs. Reyes

Petitioners: The Director of Lands, the Director of Forestry, and the Armed Forces of the Philippines.
Respondents: Hon. Salvador C. Reyes (as Judge of the Court of First Instance of Nueva Ecija, Branch III), Paranaque Investment & Development Corporation (successor of Alipio Alinsunurin), Roman C. Tamayo, the Commissioner of the Land Registration Commission, and the Register of Deeds of Nueva Ecija.
The case involves a petition for certiorari and mandamus with a preliminary injunction challenging the validity of an earlier court order related to the registration of land titles.
Subsequent to the initial proceedings, Alipio Alinsunurin was substituted by Paranaque Investment & Development Corporation as applicant and appellee.

Both respondent Paranaque Investment & Development Corporation and respondent Roman C. Tamayo asserted claims of title over the subject land.
Their claims are based on their status as heirs of the deceased Maria Padilla, relying on the "informacion posesoria" of Maria’s father, Melecio Padilla, and the alleged continuous, peaceful, and adverse possession since time immemorial.
In his answer in LRC N-675, Roman C. Tamayo did not oppose the claim of the appellant but rather stated that he, along with Alipio Alinsunurin and his wife, had been in actual and continuous possession as co-owners through their predecessors-in-interest, thereby seeking registration of title either in favor of the "testate estate of Maria Padilla" or as a specified pro indiviso share among them.

The evidence presented by respondent Paranaque Investment & Development Corporation overlaps and is inseparable from that of respondent Roman C. Tamayo.
During the hearings, Tamayo’s counsel did not introduce separate evidence but joined the evidence of Paranaque Investment & Development Corporation, emphasizing the communality of their interests and the doctrine of interdependent title claims.
The interwoven nature of the parties’ interests was a crucial fact, as any judgment affecting one would necessarily affect the other.

The petitioners appealed the entire judgment rendered in LRC N-675, not just isolated portions.
A judicial issue arose concerning the non-service of the notice of appeal to respondent Roman C. Tamayo, whose formal entry as “oppositor” was apparently made without the petitioners’ knowledge.
Despite the omission, the petitioners filed the second motion for extension of time and duly submitted the record on appeal within the prescribed period, thereby asserting that filing the record implies the filing of a notice of appeal.

A notice of lis pendens was duly entered on the Day Book of the Register of Deeds of Nueva Ecija on April 12, 1967, and later annotated on the Original Certificate of Title No. 0-3151 on June 23, 1967.
On June 5, 1967, the Supreme Court issued a restraining order to prevent the issuance of a writ of possession and any further acts of ownership until the lis pendens was properly registered.
The subsequent issuance by Judge Florendo Aquino for a “clean transfer certificate of title” occurred after the lis pendens entry, thereby raising questions about the validity of such registration given the pending adverse claim.

Whether the reversal of the judgment solely regarding Paranaque Investment & Development Corporation’s 2/3 interest necessarily implies a reversal with respect to Roman C. Tamayo’s 1/3 interest, given the interwoven and inseparable nature of their title claims.

Whether the filing of the record on appeal within the prescribed period, in the absence of a separate notice of appeal served on Roman C. Tamayo, constitutes sufficient and legally effective notice.
Whether the failure to serve Tamayo with a copy of the notice of appeal within thirty (30) days after notice of judgment violated any of his substantial rights.

Whether the registration of the notice of lis pendens on the Department of Deeds’ record in connection with the subject land provided sufficient notice to all parties of the adverse claim.
Whether this recorded lis pendens legally binds subsequent issuances of title certificates, such as the “clean transfer certificate of title” issued by Judge Florendo Aquino.

How the procedural irregularities, including non-service of the appeal notice to one of the respondents and the subsequent order for transfer of title, affect the finality and binding effect of the judgment on all parties involved.