Case Summary (G.R. No. 127941)
Background of the Case
The Court of Appeals ruled in favor of Candelario Damalerio as the absolute owner of the disputed land, a decision affirmed by the Supreme Court. Despite this ruling, the Register of Deeds refused to issue new Certificates of Title in Damalerio's name, requiring the matter to be referred to an en consulta to secure the cancellation of Banaga’s title. This led to further legal proceedings, with Banaga's attempts to redeem the property through deposits to the trial court, ultimately challenged by Damalerio.
Redemption Actions and Judicial Proceedings
Initially, the trial court determined that Banaga had lost her right to redeem the property following the foreclosure. Upon appeal, the Court of Appeals overturned this decision, allowing Banaga a period within which to complete the redemption, which she attempted by depositing the requisite amount financed by co-petitioner Tan. Nevertheless, the trial court's favorable order towards Banaga was later rescinded by the Court of Appeals, which reinstated Damalerio's ownership after finding that Banaga had failed to redeem within the stipulated time frame.
Conflict of Notices and Subsequent Actions
The dynamics of the case complicated when Banaga sold the property to Tan despite the ongoing disputes. Tan subdivided the property and sought new titles from the Register of Deeds, actions taken without judicial dispensation as the notices of lis pendens indicated the existence of prior litigation. These developments eventually led to Tan being named in Damalerio's certiorari petition.
Final Court of Appeals Ruling
The Court of Appeals ultimately granted Damalerio's petition, nullifying the previous orders that confirmed Banaga's attempted redemption and directed the issuance of new titles in Damalerio's name. This order was upheld by the Supreme Court, effectively refraining from revisiting the already adjudicated matters due to res judicata principles.
Key Legal Principles: Res Judicata
The Supreme Court emphasized the principle of res judicata, which prohibits the re-litigation of issues that have been conclusively resolved by a competent court. The findings indicated that both previous judgments pertaining to the redemption and ownership were final and must prevail, hence preventing Banaga and Tan from contesting ownership again.
Bad Faith Acquisition
The ruling critically analyzed the actions of Jovita Tan, deeming her acquisition of the property as one conducted in bad faith. Given that she was aware of the lis pendens and the ongoing litigation, the Court reiterated that her claim of being a good faith purchaser could not succeed since she failed to undertake reasonable due diligence regarding the ownership of the property.
Possession Rights and Ministerial Functions
With the Court affirming Damalerio’s ownership, it also addressed the issue of possession, stating that the right is intrinsically linked to ownership. The Supreme Court concluded that t
...continue readingCase Syllabus (G.R. No. 127941)
Background and Procedural History
- The case originated from an action for redemption filed by petitioner Banaga concerning a property earlier foreclosed and sold at public auction to private respondent Damalerio.
- The trial court initially declared petitioner Banaga lost her right to redeem the property and issued Certificates of Title to private respondent.
- Petitioner Banaga annotated a notice of lis pendens on the titles in 1983.
- On appeal, the Court of Appeals (CA) reversed the trial court decision, allowing Banaga to redeem within a certain period.
- Private respondent's petition to the Supreme Court was dismissed, making the CA decision final and executory.
- On June 11, 1992, petitioner Banaga deposited the redemption amount, financed by co-petitioner Tan.
- The trial court upheld the redemption and ordered Register of Deeds to cancel private respondent's titles and issue new ones to Banaga.
- Private respondent filed petitioner for certiorari with CA to challenge this order; a temporary restraining order was issued to enjoin execution pending review.
- Despite pending litigation and notices of lis pendens, petitioner Banaga sold the property to Tan, who subdivided it in Damalerio's name.
- New titles were issued to Tan but annotated with notices of lis pendens.
- CA later set aside trial court orders upholding Banaga's redemption and declared Damalerio absolute owner.
- The Supreme Court affirmed this decision after dismissing Banaga's motion for reconsideration.
Register of Deeds' Refusal and Enforcement Difficulties
- Trial court issued writ of execution directing Register of Deeds to reinstate titles in private respondent's name.
- Register of Deeds refused compliance, citing necessity of surrendering certificates issued to petitioner Tan.
- Private respondent's motion to cite Register of Deeds in contempt was denied; remedy suggested was consulta to the Land Registration Commissioner.
- Trial court denied writ of possession to private respondent, ruling he must file a separate action to cancel Tan's titles.
Court of Appeals' Intervention
- Private respondent filed certiorari and mandamus petition to CA.
- CA granted petition, setting aside trial court orders denying writ of possession and contempt citation.
- CA nullified titles issued to petitioners and their subsequent transferees.
- CA ordered Register of Deeds to issue new certificates in private respondent's name and instructed lower court to enforc