Case Summary (G.R. No. 184068)
Background of the Case
On February 10, 1975, Rosario T. Alzul acquired four lots in Aurora Subdivision through B.E. San Diego, Inc. under a Contract to Sell for a total price of P237,660.00, with an initial down payment followed by monthly installments. Subsequently, Alzul assigned her rights under this contract to Wilson P. Yu via a Conditional Deed of Assignment. B.E. San Diego, Inc. canceled Alzul's original contract and issued a new contract in Yu's name.
Legal Proceedings
On August 25, 1980, Alzul filed a suit for rescission against Yu, asserting that he failed to pay the consideration. The trial court ruled in favor of Alzul, and the decision was upheld by the Court of Appeals and the Supreme Court. During these proceedings, Alzul annotated a Notice of Lis Pendens on the original title of the lots on file with the Register of Deeds, putting future purchasers on alert about potential claims on the property.
Subsequent Transactions and Court Actions
In 1989, B.E. San Diego, Inc. declared the contract rescinded and sold the lots to Carlos and Sandra Ventura, who were unaware of the lis pendens annotation. The Venturas subsequently filed an action for quieting of title, which initially favored them, but the Court of Appeals later reversed this decision. The appellate court reinstated B.E. San Diego, Inc.'s title while recognizing the lis pendens annotation, affirming Alzul's rights.
Legal Issues Addressed
The central legal issue revolved around the binding nature and efficacy of the Notice of Lis Pendens. It was contended by both Yu and the Venturas that the notice, being inscribed solely on the original title held by the Register of Deeds rather than on the owner’s duplicate copy, did not provide adequate notice to them, thus precluding binding obligations as purchasers in good faith.
Court's Reasoning
The Supreme Court clarified that the annotation of a notice of lis pendens on the original title is sufficient to constitute constructive notice to subsequent purchasers. Actual notice is not necessary; therefore, purchasers are deemed alerted to any claims arising from litigation concerning the property. The court highlighted that the annotation serves as a public announcement about the property's litigation status, t
...continue readingCase Syllabus (G.R. No. 184068)
Case Overview
- Case Citation: G.R. No. 109078, December 26, 1995
- Court: Supreme Court of the Philippines, Third Division
- Petitioner: Wilson P. Yu
- Respondents: Court of Appeals, Rosario T. Alzul, Register of Deeds for Metro Manila, District III
- Justice: Panganiban, J.
Factual Background
- On February 10, 1975, Rosario Alzul purchased four lots in Aurora Subdivision, Maysilo, Malabon, Rizal (now Metro Manila) from B.E. San Diego, Inc. via Contract to Sell No. 867.
- The purchase included:
- Total area: 1,275 sq. m.
- Price: P100.00 per sq. m.
- Downpayment: P12,750.00
- Monthly installments: P1,249.50 with 12% interest until full payment, totaling P237,660.00.
- Rosario Alzul assigned her rights under the contract to Wilson P. Yu through a "Conditional Deed of Assignment and Transfer of Rights" dated July 25, 1977.
- Following the assignment, B.E. San Diego, Inc. cancelled Alzul's contract and issued a new Contract to Sell No. 867 in favor of Yu.
Legal Proceedings
- On August 25, 1980, Rosario Alzul filed a suit against Wilson P. Yu for rescission of the conditional deed, alleging non-payment of the balance.
- The trial court ruled in favor of Alzul, a decision that was affirmed by the Court of Appeals and later became final when dismissed by the Supreme Court on May 8, 1989.
- During the litigation, on September 30, 1985, Alzul annotated a Notice of Lis Pendens on the original certificate of title for the four lots.