G.R. No. L-39272 - Vda. de Medina vs. Cruz

The case emerged from Civil Case No. C-120 involving Lot 6, Grace Park Subdivision, Caloocan City, which had been under the Land Registration Act No. 496 since 1916 and covered by an Original Certificate of Title issued pursuant to Decree No. 20302 in the name of the Philippine Realty Corporation.
In 1949, Benedicta Mangahas and Francisco Ramos occupied the lot and constructed houses without the consent of the registered owner, sparking subsequent disputes over possession and ownership.

The Philippine Realty Corporation executed a Contract to Sell in 1959 in favor of Remedios Magbanua, which led to further litigation when Mangahas and Ramos instituted Civil Case No. C-120 in 1964 seeking annulment of the sale and for an alternative sale in their favor.
The lower court decided in 1969 in favor of Philippine Realty Corporation and Remedios Magbanua, directing Mangahas and Ramos to vacate the lot.
The appeal to the Court of Appeals was dismissed, and a petition for review was rejected by the Supreme Court with all subsequent motions for reconsideration denied or expunged from the records.

After the final judgment in the lower court, on November 9, 1973, the Philippine Realty Corporation executed a Deed of Sale of Lot 6 in favor of Remedios Magbanua, with Transfer Certificate of Title No. 52262 issued in her name.
In October 1973, petitioner Eugenia Salamat vda. de Medina acquired the same parcel from the Heirs of Don Mariano San Pedro y Esteban, evidenced by a Deed of Absolute Sale.
Shortly thereafter, on January 1974, the petitioner purchased six houses standing on the lot from Ricardo de Guzman and Eufrocinia de Guzman, obtaining a separate Deed of Absolute Sale.

Following the civil litigation, a petition for a writ of execution was filed on November 29, 1973, and the writ was subsequently issued in December 1973; however, service issues arose when Mangahas and Ramos refused to vacate the lot or sign the original writ.
Amid rising disputes, a motion for demolition and removal of improvements was filed by Remedios Magbanua, based on the registered title in her name and the chain of title stemming from the Philippine Realty Corporation.
The respondent Judge, after hearing opposing pleadings and motions (including those filed by petitioner against the writ of demolition), issued orders on April 5, 1974, and later on July 29, 1974, directing the demolition of the improvements on the lot if the occupants failed to vacate within a designated period.

Petitioner Eugenia Salamat vda. de Medina filed a petition for review on certiorari and injunction, challenging the enforcement of the demolition order, which was based on a decision rendered in Civil Case No. C-120—a case to which she was not a party.
She contended that as a purchaser in good faith for value and without notice from a third party (the Heirs of Don Mariano), she should not be bound by a judgment against the original occupants or related parties (Mangahas and Ramos).
The petition raised issues regarding jurisdiction, the reach of the judgment against non-parties, and the conclusive effect of Torrens Title.

Whether the final and executory decision in Civil Case No. C-120, which dismissed the complaint and ordered the occupants to vacate the lot, can be enforced against a non-party petitioner who purchased the lot and improvements in good faith.
Whether a purchaser who acquired both the lot and the improvements for value and without notice can be bound by the eviction and demolition orders rendered against the original litigants.
Whether the petitioner’s claim of ownership through good faith transaction from the Heirs of Don Mariano can shield her from the execution of the writ of demolition.
Whether the conclusive evidence provided by the Torrens Title held by Remedios Magbanua precludes the application of the demolition order to the petitioner.
Whether the payment of land taxes, as claimed by the petitioner, constitutes evidence of ownership overriding the effects of the Torrens registration and judicial proceedings.