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LETICIA P. LIGON v. CA

FACTS:

The respondent, Iglesia ni Kristo (INK), filed a complaint against the Islamic Directorate of the Philippines (IDP) for specific performance and damages relating to the sale of two parcels of land in Quezon City. INK claimed that IDP failed to evict squatters and illegal occupants as stipulated in the contract. IDP argued that INK violated the contract by delaying payment and sought to rescind the sale. INK filed a motion for partial summary judgment, which the trial court granted. INK then requested the trial court to order petitioner Leticia Ligon, who held the certificates of title as a mortgagee of IDP, to surrender the certificates for the registration of the sale in INK's name. Petitioner Ligon opposed the motion, citing issues of jurisdiction and ownership still being in dispute. However, the trial court ruled in favor of INK, ordering petitioner Ligon to surrender the certificates to INK. Petitioner Ligon filed a petition for certiorari with the Court of Appeals, but the petition was dismissed and the trial court's orders were affirmed. Petitioner Ligon now brings the case to the Supreme Court, alleging errors in jurisdiction, violation of the rule against splitting a cause of action, holding INK as the owner of the property, and granting INK the right to possession of the certificates of title. The IDP also intervened, claiming that the sale was void due to a fake board of trustees, and sought nullification of the trial court's orders based on the Securities and Exchange Commission's declaration of the sale as void.

ISSUES:

  1. Whether the trial court had jurisdiction over petitioner Ligon.

  2. Whether the orders of the trial court violated the rule against splitting of a single cause of action and forum-shopping.

  3. Whether respondent INK is the owner of the properties and entitled to registration of its ownership.

  4. Whether respondent INK has a superior right to the possession of the owner's copies of the certificates of title.

RULING:

  1. The Supreme Court did not address this issue in the partial digest provided.

  2. The Supreme Court did not address this issue in the partial digest provided.

  3. The trial court erred in ruling that respondent INK is the owner of the properties and entitled to registration of its ownership.

  4. The trial court erred in holding that respondent INK has a superior right to the possession of the owner's copies of the certificates of title.

PRINCIPLES:

  • Under the land registration law, no voluntary instrument shall be registered by the Register of Deeds unless the owner's duplicate certificate is presented together with such instrument, except in some cases or upon order of the court for cause shown.

  • If the person in possession of the duplicate certificates refuses or fails to surrender the same to the Register of Deeds for the registration of a voluntary document, the court may order the surrender of the owner's duplicate certificates.