Case Digest (G.R. No. 56290)
Facts:
- The case involves the Government Service Insurance System (GSIS) as the petitioner and Zenaida Manero, represented by her attorney-in-fact, Jose E. Castaneda, as the respondent.
- On February 7, 1975, Zenaida Manero purchased a parcel of land from Manolita G. Suntay, covered by Transfer Certificate of Title (TCT) No. 33912, which was free from encumbrances at the time of sale.
- After registering the deed of sale, TCT No. 55932 was issued in Manero's name.
- GSIS later filed an affidavit of adverse claim on Manero's title, asserting its interest as a mortgagee of the property used as collateral for a loan to Suntay.
- On October 22, 1975, Manero filed a petition with the Court of First Instance of Bataan, Branch 1, to cancel GSIS's adverse claim, arguing it was improperly annotated since the mortgage lien had been cancelled and she was a good faith purchaser with no connection to GSIS.
- GSIS opposed the petition, alleging forgery regarding the mortgage release.
- The trial court ruled in favor of Manero on July 15, 1977, ordering the cancellation of the adverse claim.
- GSIS's motion for reconsideration was denied, and the Court of Appeals affirmed the decision on November 28, 1980.
- GSIS subsequently filed a petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Court affirmed that the Court of First Instance had jurisdiction to decide the substantive issues raised in the case.
- The Court ruled that Zenaida Manero was indeed an innocent purchaser in good faith and for value.
- The Court concluded that the questi...(Unlock)
Ratio:
- The Court held that the Court of First Instance, acting as a land registration court, has the authority to resolve substantive issues during summary proceedings for the cancellation of an adverse claim, referencing Section 110 of the Land Registration Act.
- GSIS did not object to the proceedings and allowed the case to proceed as an ordinary civil action, waiving its right to contest the court's jurisdiction.
- The Court foun...continue reading
Case Digest (G.R. No. 56290)
Facts:
The case involves the Government Service Insurance System (GSIS) as the petitioner and Zenaida Manero, represented by her attorney-in-fact, Jose E. Castaneda, as the respondent. The events leading to the case began on February 7, 1975, when Zenaida Manero purchased a parcel of land from Manolita G. Suntay, which was covered by Transfer Certificate of Title (TCT) No. 33912. At the time of the sale, the title was free from any encumbrances. Following the registration of the deed of sale, TCT No. 55932 was issued in Manero's name. However, GSIS later filed an affidavit of adverse claim on Manero's title, asserting its interest as a mortgagee of the property, which had been used as collateral for a loan granted to Suntay. On October 22, 1975, Manero, through Atty. Castaneda, filed a petition with the Court of First Instance of Bataan, Branch 1, seeking the cancellation of GSIS's adverse claim. Manero argued that the adverse claim was improperly annotated since the mortgage lien on TCT No. 33912 had already been cancelled, and as a good faith purchaser, she had no privity with GSIS. The GSIS opposed the petition, presenting evidence to support its claim of interest in the property, including allegations of forgery regarding the mortgage release. The trial court ruled in favor of Manero on July 15, 1977, ordering the cancellation of the adverse claim. GSIS's subsequent motion for reconsideration was denied, and the Court of Appeals affirmed the trial court's decision on November 28, 1980. GSIS then filed a petition for review on certiorari.
Issue:
- Does the Court of Fir...