Title
Star Asset Management Ropoas, Inc. vs. Register of Deeds of Davao City
Case
G.R. No. 233737
Decision Date
Feb 3, 2021
Three parcels of land in Davao City, subject to a Compromise Agreement, were disputed after payment default. The Supreme Court ruled the adverse claim invalid, canceling it due to non-compliance with the agreement and inapplicability of the Maceda Law.

Case Summary (G.R. No. 210965)

Facts of the Case

The case revolves around three parcels of land in Barangay Baliok, Talomo, Davao City, previously registered under Transfer Certificates of Title (TCT) in the name of Star Asset. Star Asset filed for Cancellation of Adverse Claim asserting that it acquired the properties from Unimark Investments Corporation after the properties were foreclosed by the Philippine Bank of Communication and later sold. A Compromise Agreement was entered into between Star Asset and Goldland regarding the buy-back of the properties but was subsequently cancelled by Star Asset due to Goldland's failure to comply with the agreed terms.

Legal Proceedings

After the cancellation of the Compromise Agreement, Foothills Realty, as the successor-in-interest to Goldland, initiated an adverse claim on the TCTs. Star Asset petitioned for the cancellation of this annotation, arguing that the adverse claim was invalidated by the termination of the underlying Compromise Agreement. Meanwhile, Foothills Realty contested the cancellation, claiming rights under the Maceda Law and asserting that it had made substantial payments under the agreement.

Ruling of the Regional Trial Court

The Regional Trial Court (RTC) ruled against Star Asset's petition for cancellation, concluding that the cancellation of the Compromise Agreement was improper. The RTC stated that the Maceda Law applied, requiring notarial notice for valid cancellation. It found that Goldland had defaulted on payments but had not received the requisite formal communication regarding cancellation, rendering Star Asset's actions ineffective.

Ruling of the Court of Appeals

The Court of Appeals upheld the RTC's decision. It supported the applicability of the Maceda Law in this context, emphasizing that without a valid cancellation of the Compromise Agreement, Foothills Realty retained the right to assert an adverse claim. The CA dismissed Star Asset's claims, asserting that they did not have the right to cancel the adverse claim based on a purportedly invalid compromise agreement.

Petition for Review on Certiorari

Star Asset, now substituted by Dallas Energy, filed a petition for review contesting the lower courts' application of the Maceda Law to the case. Petitioner argued that Foothills Realty's adverse claim should not have been permitted and that the correct remedy was direct registration of the compromise agreement with the Register of Deeds instead of filing an adverse claim.

Ruling of the Supreme Court

The Supreme Court found merit in the petition, determining that the Maceda Law was not applicable in this instan

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