Case Digest (G.R. No. 196592)
Facts:
This is Spouses Juvy Marano and Maria Luisa G. Marano v. Pryce Gases, Incorporated, G.R. No. 196592, April 06, 2015, Second Division, Brion, J., writing for the Court. Petitioners are the Spouses Juvy and Maria Luisa Marano; respondent is Pryce Gases, Incorporated.On August 1, 1998, petitioners filed a free patent application for Lot No. 4299 (9,074 sq. m.) in Damulaan, Albuera, Leyte; an Original Certificate of Title No. P-43553 was later issued to them on December 17, 1998. On December 29, 1998 the petitioners filed an ejectment complaint against respondent alleging illegal entry and construction on the lot in March 1998. The Municipal Trial Court (MTC) of Albuera ruled for the petitioners (June 4, 1999); the Regional Trial Court (RTC) reversed (August 30, 1999); the Court of Appeals (CA) on January 11, 2002 remanded the matter to the MTC for trial as a reivindicatory action. The reivindicatory action was docketed as Civil Case No. 158 in the MTC.
Meanwhile, respondent filed a protest to petitioners’ free patent on April 17, 1999; the Department of Environment and Natural Resources (DENR) on December 29, 2000 recommended reversion proceedings (its decision became final and executory), but no reversion proceedings were instituted. On October 28, 2002 petitioners filed a quieting of title action in the RTC (Civil Case No. B-2002-10-31). In November 2002 respondent filed a reconveyance complaint in the same RTC (Civil Case No. B-2002-11-32), later amended to seek cancellation of petitioners’ certificate of title. Petitioners moved to dismiss the amended complaint for litis pendentia because of the pending reivindicatory action; the RTC denied the motion (resolution dated March 6, 2006) and denied reconsideration (order dated June 8, 2006).
Petitioners filed a petition for certiorari with the CA (docketed CA-G.R. CEB-SP No. 02025) challenging the RTC’s denial. While that petition was pending, the MTC in the reivindicatory action conducted trial and, in a decision dated June 18, 2010, ruled in favor of respondent, declaring respondent owner and entitled to possession; petitioners appealed to the RTC. On December 14, 2010 the CA (Authored by CA Associate Justice Socorro B. Inting, with Associate Justices Portia A. Hormachuelos and Edwin D. Sorongon concurring) affirmed the RTC’s dismissal of petitioners’ motion to dismiss, holding there was no litis pendentia between the MTC reivindicatory action and th...(Pro-only)
Issues:
- Did the Court of Appeals err in holding that there was no litis pendentia between the reivindicatory action pending before the MTC (on appeal to the RTC) and the respondent’s cancellation of certificate of title case in the RTC?
- If litis pendentia did exist or the cases involve a common question, should the cancellation case have been dismissed or consolidated with the reivindicatory action?
- Was respondent’s complaint for cancellation of the petitioners’ Torrens title a proper direc...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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