Case Digest (A.M. OCA IPI No. 08-127-CA-J)
Facts:
Raul F. Saberon, Jr., Joan F. Saberon and Jacqueline Saberon v. Oscar Ventanilla, Jr. and Carmen Gloria D. Ventanilla, G.R. No. 192669, April 21, 2014, Supreme Court Third Division, Mendoza, J., writing for the Court. The petition under consideration was a motion for reconsideration of this Court's January 19, 2011 Resolution that had denied the Saberons' petition seeking relief from the March 12, 2010 Decision and June 18, 2010 Resolution of the Court of Appeals in CA-G.R. CV No. 85520.The dispute traces to contracts to sell entered on March 3, 1970 in favor of Oscar and Carmen Ventanilla (the Ventanillas) by Manila Remnant Co., Inc. (MRCI) and the subsequent misconduct of A.U. Valencia & Co., Inc. (AUVC) and its president Artemio Valencia, who diverted payments and, without the Ventanillas' knowledge, caused the same lots to be shown sold to a Carlos Crisostomo. Litigation followed: the Court of First Instance (Quezon City) on November 17, 1980 declared the Ventanillas' contracts valid and ordered MRCI to execute absolute deeds of sale; the Court of Appeals affirmed; this Court, in G.R. No. 82978 (Nov. 22, 1990) and later in G.R. No. 107282 (Mar. 16, 1994), likewise affirmed aspects of those rulings, including that a subsequent sale to Samuel Marquez could not prevail over the final and executory judgment in favor of the Ventanillas.
While execution proceedings were pending, a notice of levy was entered in the Registry of Deeds primary entry book on May 31, 1991. MRCI later executed a deed of sale to Samuel Marquez, and Marquez subsequently sold to the Saberons, who paid value and obtained Transfer Certificates of Title (TCTs) issued in July 1992. The levy was not carried over to the later titles due to the Register of Deeds’ failure to annotate the TCTs.
The Ventanillas filed Civil Case No. Q-96-26486 in the Regional Trial Court (Branch 80, Quezon City) to annul the deeds to Marquez and to the Saberons. On June 21, 2005 the RTC declared the TCTs in Marquez’s and the Saberons’ names null and void, ordered cancellation and reissuance to the Ventanillas upon compliance, and awarded damages; it also found the Saberons to be builders in good faith and awarded them compensation against the other defe...(Subscriber-Only)
Issues:
- Did the registration of the Ventanillas' notice of levy in the Registry of Deeds primary entry book constitute constructive notice binding third parties despite the Register of Deeds' failure to annotate the levy on subsequent certificates of title?
- Were the Saberons purchasers in good faith and for value entitled to rely on clean certificates of title such that their TCTs were indefeasible?
- Had the Ventanillas' rights under the earlier final judgments ripened into ownership and could their claim be defeated by laches?
- What remedies are available to the Saberons as builders in good faith with improvements on the lots — are they entitled to indemnity under Article 448 in relation to Articl...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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