Title
Government Service Insurance System vs. Court of Appeals
Case
G.R. No. 56290
Decision Date
Jan 30, 1995
The Supreme Court confirms the Court of Appeals' ruling to annul GSIS's adverse claim on property purchased by good faith buyer Zenaida Manero, whose mortgage lien has been settled.
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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

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