Case Summary (G.R. No. 156076)
Applicable Law
The legal issues addressed in this case are governed by the provisions outlined in Presidential Decree No. 1529, known as the Property Registration Decree, alongside relevant principles from the Civil Code concerning property ownership and registration.
Background of the Case
Petitioners Jesus Ching and Lee Poe Tin purchased a 370-square meter lot from Raymunda La Fuente on September 5, 1985, and were provided with a Deed of Absolute Sale along with the Owner’s Duplicate Certificate of Title. Notably, despite this purchase, the transaction was not registered with the Register of Deeds, as mandated by Section 51 of PD 1529. Instead, on November 20, 1986, the petitioners filed an Affidavit of Adverse Claim, which was subsequently annotated on TCT No. 83618.
Development of Events
The situation escalated when, on August 19, 1988, petitioners received a Notice of Levy on Attachment from the RTC of Pasig in favor of respondents relating to an execution against La Fuente. The respondents then acquired the property through a Certificate of Sale dated January 26, 1989. In response to the conflicting claims, petitioners filed a complaint to quiet title on January 8, 1990.
Regional Trial Court Ruling
On May 11, 1993, the RTC ruled in favor of the petitioners, asserting their superior claim over the property based on the earlier registration of their Affidavit of Adverse Claim compared to the Certificate of Sale in favor of respondents. The RTC ordered the cancellation of the annotations favoring the respondents and awarded damages to the petitioners.
Court of Appeals Decision
Respondents appealed to the Court of Appeals (CA), arguing that the RTC erred in its ruling. The CA, in its decision dated August 29, 2002, recognized the sale to petitioners as valid but ultimately reversed the RTC's decision, asserting that petitioners failed to protect their interests adequately by not formally registering their Deed of Absolute Sale.
Key Legal Principles
The CA highlighted important legal principles under PD 1529, specifically that registration is the operative act to convey rights concerning registered land. It emphasized that a deed or claim, to be enforceable against third parties, must be registered. Respondents maintained that the annotation of the petitioners’ adverse claim had expired within the 30-day period prescribed by the law, thus negating its efficacy when they acquired the property.
Supreme Court's Analysis
Upon petitioning to the Supreme Court, the Court found merit in the petitioners’ case, particularly contesting the CA's ruling on the expiration of the adverse claim. The Supreme Court clarified that an adverse claim remains valid even after 30 days unless a petition for cancellation has been filed. The Court underscored that the existence o
...continue readingCase Syllabus (G.R. No. 156076)
Case Background
- This case involves a petition for review on certiorari filed by the petitioners, Jesus Ching and Lee Poe Tin, against the decision of the Court of Appeals (CA) dated August 29, 2002, and its subsequent resolution denying the motion for reconsideration.
- The CA decision reversed the ruling of the Regional Trial Court (RTC) of Makati City, which had favored the petitioners in their action for quieting of title against the respondents, Adolfo and Arsenia Enrile.
Facts of the Case
- On September 5, 1985, the petitioners purchased a 370-square meter lot in Barrio Tungtong, Las Piñas, from Raymunda La Fuente, which was covered by Transfer Certificate of Title (TCT) No. 83618.
- The petitioners received a duly notarized Deed of Absolute Sale and took possession of the property; however, they did not register the sale with the Register of Deeds, as required by Section 51 of Presidential Decree (PD) 1529.
- Instead, on November 20, 1986, they recorded an Affidavit of Adverse Claim against the title.
- The petitioners maintained peaceful possession until they received a Notice of Levy on Attachment and Writ of Execution from the RTC of Pasig on August 19, 1988, which were entered against the property in favor of the respondents due to a separate case involving La Fuente.
- The Certificate of Sale from the execution sale was subsequently annotated in favor of the respondents on January 26, 1989.