Case Summary (G.R. No. 214241)
Factual Background
In 1997 Spouses Ramon and Ligaya Gonzales filed a Complaint for Recognition as Tenant with Damages and Temporary Restraining Order against Marmaine Realty Corporation before the Provincial Adjudicator, Department of Agrarian Reform Adjudication Board (the Tenancy Case). Marmaine Realty Corporation filed an Answer with Counterclaim and contested the complaint. The Provincial Adjudicator issued a writ of preliminary injunction in favor of Spouses Gonzales on January 6, 1998. A Notice of Lis Pendens was registered with the Register of Deeds of Batangas and annotated on the certificates of title of Marmaine Realty Corporation on September 26, 2000.
Proceedings Before the Adjudicatory Bodies
After trial, the Provincial Adjudicator dismissed the complaint of Spouses Gonzales in a Decision dated June 27, 2002. A motion for reconsideration was denied on August 7, 2002. Spouses Gonzales appealed to the DARAB, which affirmed the Provincial Adjudicator in a Decision dated October 17, 2008; a motion for reconsideration of the DARAB decision was denied on March 23, 2009. The DARAB ruling became final and executory on May 7, 2009, and an Entry of Judgment issued on January 19, 2012.
Motion for Cancellation of Lis Pendens and PARAD Rulings
Following the finality of the DARAB decision, Marmaine Realty Corporation filed a Motion for Cancellation of Notice of Lis Pendens on January 31, 2012. The Provincial Adjudicator initially denied the motion in an Order dated May 15, 2012 on grounds including prematurity because a civil case between the parties was pending before the Regional Trial Court of Rosario, Batangas, Branch 87, docketed as Civil Case No. RY2K-052. On reconsideration, the Provincial Adjudicator set aside the earlier Order and, in an Order dated December 4, 2012, directed the Register of Deeds to cancel the annotation of lis pendens on Marmaine Realty Corporation’s certificates of title. The Provincial Adjudicator specified that the cancellation pertained solely to the Tenancy Case and would not affect Civil Case No. RY2K-052. A motion for reconsideration by Spouses Gonzales was denied in a Resolution dated October 16, 2013.
Court of Appeals Proceedings
Dissatisfied with the PARAD denial of reconsideration, Spouses Gonzales filed a petition for review under Rule 43, Rules of Court with the Court of Appeals on December 13, 2013. In a Resolution dated April 24, 2014, the Court of Appeals dismissed the petition for non-exhaustion of administrative remedies, holding that the proper recourse from a PARAD denial of a motion for reconsideration was an appeal to the DARAB and not a Rule 43 petition. The Court of Appeals denied a motion for reconsideration on September 10, 2014.
Issues Presented
The Supreme Court framed the issues as: (a) whether the Court of Appeals erred in dismissing the petition for review on the ground of non-exhaustion of administrative remedies; and (b) whether the Provincial Adjudicator correctly ordered the cancellation of the notice of lis pendens annotated on Marmaine Realty Corporation’s certificates of title.
Doctrine of Exhaustion of Administrative Remedies and Its Exception
The Court reiterated that the doctrine of exhaustion of administrative remedies requires courts to allow administrative agencies to decide matters within their specialized competence, thus promoting economy, speed, and comity. The Court acknowledged that the doctrine is not absolute and recognized the established exception where the question presented is purely legal and ultimately requires judicial determination. The Court relied on Vigilar v. Aquino for the proposition that when the issue turns on the interpretation and application of law rather than on the probative value of evidence, exhaustion does not apply because administrative authorities cannot finally resolve such legal questions.
Application of the Exception to the Present Case
The Court found that the question whether the cancellation of the Notice of Lis Pendens was proper presented a purely legal issue. The resolution of that issue did not require examination of probative facts but rather a legal determination of the consequences of a final adjudication in the Tenancy Case on the annotation of lis pendens. Because the question fit within the recognized exception to the exhaustion doctrine, the Court held that the Court of Appeals erred in dismissing the petition on the ground of non-exhaustion.
Legal Principles Governing Lis Pendens and Its Cancellation
The Court explained that lis pendens denotes the control a court acquires over property involved in pending litigation and that the filing of a notice of lis pendens serves to keep the property within the court’s power and to bind subsequent purchasers. The Court cited Section 14, Rule 13 of the Rules of Court, which allows cancellation of a notice of lis pendens upon proper showing that it was used to molest the adverse party or was unnecessary to protect the annotating party’s rights. The Court further
...continue reading
Case Syllabus (G.R. No. 214241)
Parties and Procedural Posture
- SPOUSES RAMON AND LIGAYA GONZALES filed a Complaint for Recognition as Tenant with Damages and Temporary Restraining Order before the Office of the Provincial Adjudicator, DARAB, Region IV.
- MARMAINE REALTY CORPORATION, REPRESENTED BY MARIANO MANALO opposed the Complaint and filed an Answer with Counterclaim after a prior Motion to Dismiss.
- The Provincial Adjudicator issued a writ of preliminary injunction in favor of SPOUSES RAMON AND LIGAYA GONZALES, whereupon they caused a Notice of Lis Pendens to be annotated on MARMAINE REALTY CORPORATION’s certificates of title.
- After final and executory rulings adverse to SPOUSES RAMON AND LIGAYA GONZALES in the Tenancy Case, MARMAINE REALTY CORPORATION moved before the PARAD for cancellation of the Notice of Lis Pendens.
- The PARAD ultimately ordered cancellation of the Notice of Lis Pendens, and SPOUSES RAMON AND LIGAYA GONZALES elevated the matter to the Court of Appeals by a petition for review under Rule 43, Rules of Court.
- The Court of Appeals dismissed the petition for review on the ground of non-exhaustion of administrative remedies, and the Supreme Court resolved the present petition for review on certiorari.
Key Factual Allegations
- SPOUSES RAMON AND LIGAYA GONZALES filed the Tenancy Case on October 30, 1997 before the Provincial Adjudicator.
- The Provincial Adjudicator issued a Resolution on January 6, 1998 ordering a writ of preliminary injunction in favor of SPOUSES RAMON AND LIGAYA GONZALES.
- SPOUSES RAMON AND LIGAYA GONZALES caused a Notice of Lis Pendens dated September 26, 2000 to be annotated on MARMAINE REALTY CORPORATION’s titles.
- The Provincial Adjudicator rendered a Decision dated June 27, 2002 dismissing the Tenancy Case, and the DARAB affirmed that Decision on October 17, 2008, with denial of subsequent motions for reconsideration and finality of the DARAB Decision on May 7, 2009.
- MARMAINE REALTY CORPORATION filed a Motion for Cancellation of Notice of Lis Pendens on January 31, 2012, which the PARAD initially denied as premature on May 15, 2012 because a civil case between the same parties remained pending in RTC, Branch 87, Civil Case No. RY2K-052.
- On reconsideration, the PARAD set aside its earlier Order by Decision dated December 4, 2012 and directed the Register of Deeds to cancel the annotation of the Notice of Lis Pendens as to the Tenancy Case, and it denied petitioner’s motion for reconsideration on October 16, 2013.
Procedural History
- SPOUSES RAMON AND LIGAYA GONZALES appealed the PARAD Decision to the DARAB, which affirmed the dismissal of the Tenancy Case.
- MARMAINE REALTY CORPORATION secured an Entry of Judgment on January 19, 2012 following finality of the DARAB Decision.
- MARMAINE REALTY CORPORATION obtained a PARAD Order cancelling the Notice of Lis Pendens on