Case Summary (G.R. No. 255989)
Factual Antecedents
On October 6, 1993, the heirs of Manuel Uy Ek Liong, represented by Belen Uy, filed for the registration of a notice of lis pendens affecting several properties, intending to bind these properties under their claim. The notice of lis pendens was duly entered but the subsequent paperwork process was flawed when the original title for the property in question was found missing. This led to issues when the Spouses Garana purchased the property from Leovina Jalbuena, who had failed to surrender the duplicate title for proper annotation of the lis pendens. The sale was executed after the cancellation of a prior adverse claim annotation, which had been unrelated to the heirs' later claims.
The Trial Court's Decision
The Regional Trial Court ruled in favor of the Register of Deeds, allowing the annotation of the notice of lis pendens despite the prior actions taken by the Spouses Garana based on their reliance on a clear title. The Spouses Garana contested this decision, claiming it would unjustly prejudice their rights as innocent purchasers.
The Court of Appeals' Ruling
The Court of Appeals reversed the trial court’s decision, emphasizing that the property is registered under the Torrens System. It stressed that parties dealing with such titled properties should rely on the accuracy of the title presented. The CA concluded that the Spouses Garana were innocent purchasers, as they purchased the property without knowledge of the pending claims due to the lack of any notation.
The Petition
In seeking relief from the Court of Appeals' decision, the petitioner acknowledged shortcomings in annotating the notice of lis pendens but argued that the prior registration in the primary entry book was sufficient to bind all persons dealing with the property. The petitioner referred to the precedent set in Levin v. Bass, asserting that registration in the primary book grants constructive notice to all stakeholders.
The Issue
The central question was whether the register's failure to annotate the notice of lis pendens on the title negates its binding effect when it was registered properly in the primary entry book.
The Court’s Ruling
The Supreme Court granted the petition. It held that previous jurisprudence established that the mere entry of a notice of lis pendens in the primary entry book effectively provides notice to all parties, thereby binding them to the claim. The Court reaffirmed that the documentation procedures and their compliance with earlier laws allow an involuntary claim to be recognized despite its absence on the physical title.
Good Faith and Due Diligence
The Court indic
...continue readingCase Syllabus (G.R. No. 255989)
Case Overview
- The case involves a petition for review on certiorari challenging the decisions of the Court of Appeals (CA) regarding the order of the Regional Trial Court (RTC) to annotate a notice of lis pendens on a property title.
- The CA annulled the RTC's order, leading to this appeal.
Factual Antecedents
- On October 6, 1993, the heirs of Manuel Uy Ek Liong, represented by Belen Uy, sought the registration of a notice of lis pendens affecting several titles, including TCT No. T-72029.
- The notice was registered in the primary entry book of RD Lucena, but TCT No. T-72029 was not annotated due to the original title being missing and the owner's failure to surrender the duplicate copy.
- The Spouses Garana purchased the property from Leovina Jalbuena, unaware of the pending notice of lis pendens, after the cancellation of an earlier adverse claim by Belen Uy.
Procedural History
- The heirs of Manuel Uy later discovered the sale and requested the annotation of the notice of lis pendens on the Spouses Garana's new title (TCT No. T-77739).
- The RTC granted the petition to annotate the notice, but the Spouses Garana and Far East Bank opposed the annotation, arguing it would prejudice them as innocent p