G.R. No. L-30670 - Tanchoco vs. Aquino

The petition for certiorari with preliminary injunction sought the annulment of several orders (dated June 25, 1968; July 31, 1968; March 14, 1969; and May 29, 1969) issued by the Court of First Instance of Nueva Ecija, Branch I in Civil Case No. 8077.
The orders involved the adjudication, cancellation, and subsequent transfer of titles covering an undivided one-half of Lot 314, originally described under T.C.T. No. 11682.

Petitioners: Pastor Tanchoco, Macario Tanchoco, Agripina Tanchoco, Inocencia Tanchoco, Liberata Tanchoco, and Trinidad Tanchoco.
Private Respondents: Donato Lajom (and later his heirs Vicenta T. Vda. de Lajom and Jose T. Lajom) along with other parties involved in the litigation regarding the estate of the late Dr. Maximo Viola.
Respondents also included Rafael Viola (and his successors), who was involved in sales of interests in Lot 314 despite a pending judicial process.

The factual background originates from earlier proceedings (Civil Case No. 8077) involving disputes over the partition, adjudication, and distribution of the estate of Dr. Maximo Viola.
An earlier decision in G.R. No. L-6457 (May 30, 1956) had already adjudicated issues related to the inheritance of the estate, including the status of Lot 314.

On April 6, 1964, Rafael Viola sold an undivided one-half portion of Lot 314 (western part) to petitioners Pastor, Macario, and Agripina Tanchoco.
On January 5, 1965, Rafael Viola sold a 6/7 portion of the remaining half (eastern part) of Lot 314 (parcel No. 2) to petitioners Inocencia, Liberata, and Trinidad Tanchoco.

Prior to the sales, a notice of lis pendens (entered January 11, 1950 under Entry No. 19553/T-14707 on TCT No. 11682) warned that the property was subject to litigation.
The lis pendens was meant to alert any purchaser that the property was under dispute.

The lower court rendered several orders setting aside previous partition actions and enforcing the later judgment in Civil Case No. 8077.
Donato Lajom filed a motion for contempt, seeking the return of Lot 314 to the estate and questioning the validity of the subsequent sales made by Rafael Viola.
A subsequent order on June 15, 1967, directed that the lis pendens be annotated on the new titles (TCT Nos. NT-66683 and NT-66684) derived from the original TCT No. 11682.

On July 10, 1967, a compromise agreement was reached between the Lajoms, the Violas, and other parties to settle disputes regarding the estate.
The agreement, however, maintained the litigation regarding Lot 314 pending final resolution of issues arising from the motion for contempt.
Further motions and filings followed, including petitions for approval of the compromise agreement and motions for execution and writ of possession.

Petitioners as defendants in the contempt phase entered special appearances to object to the jurisdiction and the separate issues of the motion for the return of the lot.
The case underwent further adjudication sessions, pleadings, and memoranda culminating in oral arguments on October 1, 1969.
Additional motions to dismiss were raised by the Lajoms on the grounds of pending identical proceedings in another action.
The petition for certiorari and preliminary injunction was eventually resolved after extensive filings, hearings, and the issuance of multiple orders by the lower court.

The principal orders (June 25, 1968; July 31, 1968; March 14, 1969; and May 29, 1969) were directed towards:

Cancelling annotations and earlier titles acquired after the lis pendens was inscribed.
Executing the judgments of partition and distribution of the estate as adjudicated in Civil Case No. 8077.
Ordering the delivery of the properties under dispute to a judicial administrator pending a final resolution of the estate distribution.

The writ of execution and writ of possession issued on May 29, 1969 were central to enforcing the court’s decision, though later contested by petitioners.

Whether petitioners were deprived of procedural due process in the rendering of the lower court’s orders (June 25, 1968; July 31, 1968; March 14, 1969; and May 29, 1969).
The contention centered on whether the notice given, the special appearance, and subsequent actions by petitioners were sufficient to meet their rights to due process, particularly in the context of a motion for contempt.

Whether the annotation of the notice of lis pendens on TCT No. 11682 and its subsequent reflection on the new titles invalidated the rights of the petitioners as purchasers.
Whether the petitioners, having acquired the property with knowledge of the encumbrance, could later claim protection as purchasers in good faith.

Whether the special appearance by the petitioners, limited to objection on jurisdiction, was sufficient to split their participation in the broader litigation involving multiple reliefs and subsequent actions.