SPS. MICHAELANGELO v. HUMBERTO D. MEER

FACTS:

The case involves a petition for review on certiorari filed before the Supreme Court, challenging the Resolutions of the Court of Appeals denying the petitioners' Petition for Relief from Judgment and the subsequent denial of their motion for reconsideration. The respondent, Humberto Meer, is the registered owner of a parcel of land in Pandacan, Manila.

In June 1993, Meer discovered that his certificate of title was cancelled and a new one was issued in the name of spouses Sergio and Lerma Bunquin, who supposedly acquired the property through a deed of sale. Meer filed for the cancellation of the new certificate of title, and a notice of lis pendens was annotated on it.

While the case was pending, the new certificate of title was cancelled and replaced by a new one in the name of the petitioners, spouses Michaelangelo and Grace Mesina. The petitioners claimed to have acquired the property before the lis pendens was annotated and acted in good faith when they purchased it.

The trial court ruled in favor of the petitioners, declaring them as buyers in good faith. However, on appeal, the Regional Trial Court ruled that the petitioners were not purchasers in good faith because the registration of the deed of sale was subsequent to the annotation of the lis pendens. The Court of Appeals affirmed this ruling.

The petitioners then filed a Petition for Relief from Judgment, alleging extrinsic fraud, mistake, and excusable negligence.

ISSUES:

  1. Whether the petition for relief from judgment filed by the petitioners should be granted based on the grounds of extrinsic fraud, mistake, excusable negligence, and substantial defense.

RULING:

  1. The Court of Appeals denied the petition for relief from judgment filed by the petitioners. The court found that the grounds raised by the petitioners, including extrinsic fraud, mistake, excusable negligence, and substantial defense, were not sufficient to warrant the setting aside of the judgment. The court held that the petitioners failed to show clear and convincing evidence to support their allegations of fraud, mistake, or negligence. The court also found that the petitioners' alleged defense did not have merit and was merely a rehash of the arguments already presented and rejected by the trial court and the appellate court.

PRINCIPLES:

  • Every person dealing with registered land may rely on the correctness of the certificate of title and the law will no longer oblige them to go beyond the certificate to determine the property's condition.

  • Persons dealing with property covered by a Torrens certificate of title are not required to go beyond what appears on the face of the title.

  • The registration of a deed of sale does not confer title to the property if it is registered subsequent to the annotation of a lis pendens. The efficacy of the belatedly registered deed of sale depends on the outcome of the case for which the lis pendens was annotated.