Title
Valderama vs. Arguelles
Case
G.R. No. 223660
Decision Date
Apr 2, 2018
Dispute over land ownership in Sampaloc, Manila; adverse claim vs. lis pendens annotations; SC ruled adverse claim cannot be canceled solely due to lis pendens.

Case Digest (G.R. No. 223660)
Expanded Legal Reasoning Model

Facts:

  • Petition to cancel adverse claim
    • On December 11, 2009, respondents Sonia and Lorna Arguelles filed before RTC Branch 4, Manila (Case No. P-09-499, LRC Rec. No. 2400) a petition to cancel an adverse claim annotated as Entry No. 8957/Vol. 132 on TCT No. 266311.
    • They alleged that on November 18, 2004, Conchita A. Francia (registered owner of TCT No. 180198) executed an absolute deed of sale of the one-thousand sqm property in Sampaloc, Manila, in their favor, and the property was thereafter registered under TCT No. 266311.
  • Adverse claim, death, and opposition
    • On November 14, 2007, Conchita filed an affidavit of adverse claim, which was annotated on TCT No. 266311; she died on January 24, 2008, transmitting her rights to her heirs.
    • On February 10, 2010, petitioner Lourdes Valderama and Tarcila Lopez, as full-blooded sisters and heirs, filed an opposition alleging the sale to respondents was simulated—pointing to Conchita’s continuous possession, tax payments, and retention of the owner’s duplicate title.
  • Lis pendens, RTC resolutions, and interlocutory motions
    • While the cancellation petition was pending, respondents filed on September 24, 2013 a separate complaint for recovery of ownership and possession (Civil Case No. 13130761, RTC Branch 47, Manila). On October 22, 2013, petitioner and Lopez annotated a notice of lis pendens on TCT No. 266311.
    • On November 21, 2013, respondents moved for outright cancellation of the adverse claim as moot and academic due to the lis pendens. On April 11 and July 31, 2014, the RTC issued resolutions cancelling the adverse claim, noting that lis pendens rendered the cancellation ministerial and without prejudice to the substantive issues in the related action.
  • Appeals and petition for certiorari
    • Petitioner and Lopez moved for reconsideration before the RTC, which was denied, and they appealed to the Court of Appeals (CA) raising a sole assignment of error: that the adverse claim was cancelled solely because of the subsequent lis pendens.
    • On December 14, 2015, the CA dismissed the appeal for raising only questions of law under Rule 50 and upheld the RTC. Reconsideration was denied on February 24, 2016. Petitioner then filed a petition for review on certiorari under Rule 45 before the Supreme Court.

Issues:

  • Procedural question
    • Did the CA correctly dismiss the appeal as raising only questions of law, requiring a petition for certiorari instead?
  • Jurisprudential applicability
    • Is Villaflor v. Juezan applicable to render the petition for cancellation of adverse claim moot and academic?
  • Substantive question
    • Can an adverse claim on a certificate of title be cancelled solely on the ground of a subsequent notice of lis pendens on the same title?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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