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SPS. ROBERT DINO v. CA

FACTS:

The case involves a dispute over the ownership of a parcel of land in Cebu City. Consorcia Sombrio, the registered owner of the land, was deceived into signing a Deed of Sale by Maria Ching, leading to the cancellation of TCT No. 67441 and the issuance of TCT No. 87156 in Ching's name. Sombrio filed a lawsuit against Ching and the notary public, Ciriaco Alcazar, seeking the annulment of the sale and the cancellation of TCT No. 87156.

During the litigation, Sombrio and Ching reached a compromise agreement stating that Sombrio was coerced into filing the case and that the deed of sale between them was valid. The agreement resulted in a decision in favor of Ching, canceling TCT No. 73069 and replacing it with TCT No. 87156.

Sombrio appealed the decision to the Court of Appeals, arguing that the compromise agreement was entered into under dubious circumstances. While the appeal was pending, Ching sold the property to Robert and Cristina Dino, who obtained TCT No. 87156.

The Court of Appeals later set aside the decision approving the compromise agreement, ordered the cancellation of the deed of sale, and directed the Register of Deeds to reinstate TCT No. 67441 in Sombrio's name or issue a new one.

Sombrio filed a motion for execution, which was granted by the trial court. However, when the Deputy Provincial Sheriff went to the Register of Deeds to execute the writ, it was discovered that TCT No. 73069 had already been cancelled and transferred to the petitioners, Robert and Cristina Dino.

As a result, Sombrio filed a motion for the issuance of a writ of possession, which was granted by the trial court. The Register of Deeds was ordered to implement the judgment of the Court of Appeals, directing the Provincial Sheriff to place Sombrio in possession of the property.

ISSUES:

  1. Whether the Court of Appeals acted with grave abuse of discretion in ordering the cancellation of petitioners' Transfer Certificate of Title of the subject property.

  2. Whether petitioners have acquired the subject property in good faith and for value.

  3. Whether or not the notice of lis pendens in a previous case binds subsequent purchasers of the property.

  4. Whether or not the petitioners are bound by the decision in the previous case even though they were not summoned and given notice of the case.

RULING:

  1. The Court finds that the Court of Appeals did not act with grave abuse of discretion in ordering the cancellation of petitioners' Transfer Certificate of Title. The trial court directed the Register of Deeds to implement the final judgment of the Court of Appeals, which included the cancellation of the said title. The cancellation was necessary in order to reinstate the original Transfer Certificate of Title in the name of the plaintiff-appellant. The Court of Appeals acted within its authority in issuing such order.

  2. The Court did not provide a ruling on whether the petitioners acquired the subject property in good faith and for value. This issue was not addressed in the partial digest provided.

  3. The notice of lis pendens in a previous case does not bind subsequent purchasers of the property if the notice has been cancelled and the subsequent purchasers were not aware of its existence. Lis pendens only affects the parties to the case and the whole world if the notice is duly registered and annotated on the certificate of title.

  4. The petitioners are not bound by the decision in the previous case because they were not summoned and given notice of the case. The impleading of the petitioners as additional defendants in the execution stage of the case violated their right to due process. As innocent purchasers for value of the property, they are not bound by the decision and the order involving them is null and void.

PRINCIPLES:

  • The Court has the authority to order the cancellation of a transfer certificate of title in order to implement a final judgment.

  • The acquisition of property in good faith and for value may affect the determination of a rightful claimant or successor-in-interest, but this issue was not ruled upon in this case.

  • Lis pendens only affects parties to the case and subsequent purchasers if the notice is duly registered and annotated on the certificate of title.

  • Innocent purchasers for value of registered land are not required to go behind the register and investigate the title of the vendor beyond what is stated on the certificate of title.

  • Impleading subsequent purchasers in a case without notice of lis pendens and without giving them a chance to be heard violates their right to due process.

  • Registration of land under the Torrens system extinguishes all claims, liens, and encumbrances asserted prior to registration except statutory liens and those noted in the certificate of title.