Case Summary (G.R. No. 214241)
Motion to Cancel Lis Pendens and PARAD Ruling
Marmaine moved on January 31, 2012 to cancel the lis pendens. The PARAD initially denied the motion as premature in view of a parallel civil case before the RTC. Upon reconsideration, however, the PARAD on December 4, 2012 ordered cancellation, finding that the agrarian tenancy case was finally resolved against Spouses Gonzales. A further motion for reconsideration by the Gonzaleses was denied on October 16, 2013.
CA Proceedings and Rationale for Dismissal
Rather than appealing to the DARAB, Spouses Gonzales filed a petition for review under Rule 43 before the Court of Appeals. In its April 24, 2014 Resolution (affirmed September 10, 2014), the CA dismissed the petition for failure to exhaust available administrative remedies, holding that the proper recourse from a PARAD denial is an appeal to the DARAB, not a Rule 43 petition.
Doctrine of Exhaustion of Administrative Remedies
Under the 1987 Constitution and settled jurisprudence, courts may not intervene until administrative remedies have been fully pursued. The doctrine ensures that specialized agencies resolve matters within their expertise, promotes efficiency, and avoids piecemeal litigation. Absent waiver or estoppel, premature court intervention is fatal to the cause of action.
Exception for Pure Questions of Law
An exception applies when the issue is purely a question of law requiring only legal interpretation, not factual or evidentiary determinations. In such cases, administrative bodies can render only a tentative ruling, and final resolution rests with the judiciary. The propriety of cancelling a lis pendens under Section 14, Rule 13 involves solely the application of law to undisputed facts.
Analysis of Lis Pendens Cancellation
Lis pendens ensures that property in litigation remains subject to court control pending final judgment and warns potential purchasers. Under Section 14, Rule 13, cancellation is warranted when the notice is merely to molest, unnecessary to protect rights, or when judgment has been rendered against the annotating party. Here, the agrarian tenancy compl
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Facts
- On October 30, 1997, Spouses Ramon and Ligaya Gonzales (Sps. Gonzales) filed a Complaint for Recognition as Tenant with Damages and Temporary Restraining Order against Marmaine Realty Corporation (Marmaine) before the DARAB Provincial Adjudicator (Tenancy Case).
- Marmaine first moved to dismiss, then filed an Answer with Counterclaim on November 29, 1997, initiating trial.
- On January 6, 1998, the PARAD ordered the issuance of a writ of preliminary injunction in favor of Sps. Gonzales.
- Sps. Gonzales caused a Notice of Lis Pendens to be annotated on Marmaine’s certificates of title on September 26, 2000.
- On June 27, 2002, the PARAD rendered a Decision dismissing the Tenancy Case for lack of merit; Reconsideration was denied on August 7, 2002.
- Sps. Gonzales appealed to the DARAB, which affirmed the PARAD Decision on October 17, 2008; their motion for reconsideration was denied on March 23, 2009.
- The DARAB Decision became final and executory on May 7, 2009, with Entry of Judgment issued January 19, 2012.
PARAD’s Cancellation Proceedings
- On January 31, 2012, Marmaine moved for cancellation of the Lis Pendens annotation.
- On May 15, 2012, the PARAD initially denied the motion as premature due to a pending civil case (Civil Case No. RY2K-052) in RTC Rosario, Batangas.
- Upon reconsideration, on December 4, 2012, the PARAD set aside its earlier order and directed the Register of Deeds to