GR L 69303; (July, 1987) (Digest)
G.R. No. L-69303; July 23, 1987
HEIRS OF MARIA MARASIGAN, petitioners, vs. THE INTERMEDIATE APPELLATE COURT and MARIA MARRON, respondents.
FACTS
The property in dispute is a residential lot originally registered under Fe Springael-Bazar. On April 24, 1975, respondent Maria Marron filed Civil Case No. 97479 to compel the Bazar spouses to execute a deed of absolute sale in her favor. During the pendency of this suit, Marron caused the annotation of a notice of lis pendens on the title on January 27, 1976. The trial court ruled in Marron’s favor on February 24, 1976, ordering the Bazaars to execute the sale. This judgment became final and executory.
However, the Bazaars had previously sold the same lot to Maria Marasigan under a deed dated December 18, 1974. This deed was only registered on July 5, 1977, resulting in the cancellation of the Bazaars’ title and the issuance of a new one in Marasigan’s name, which carried over the annotated notice of lis pendens. Marron, after obtaining a writ of execution, faced difficulties in registering the court-ordered deed due to Marasigan’s title. Marron subsequently filed Civil Case No. 126378 seeking cancellation of Marasigan’s title.
ISSUE
Who has a better right to the property, Marasigan (as a subsequent buyer) or Marron (in whose favor the notice of lis pendens was annotated and who obtained a favorable final judgment)?
RULING
The Supreme Court affirmed the appellate court’s decision in favor of Marron. The legal logic centers on the effect of a notice of lis pendens. A purchaser of property with such an annotation is conclusively deemed to have acquired it subject to the outcome of the pending litigation. Marasigan’s title, derived from the Bazaars after the lis pendens was annotated, was therefore acquired with constructive notice of Marron’s claim. Consequently, Marasigan is bound by the final judgment in Civil Case No. 97479, which validated Marron’s right to the property.
The Court also upheld the finality of the judgment in Marron’s favor, noting that the Bazaars’ petition for relief was filed out of time. Thus, the deed of sale executed by the Clerk of Court pursuant to the final judgment was valid. Marron’s superior right, stemming from the annotated notice and the final judgment, prevails over Marasigan’s registered title, which was subject to the lis pendens. The Register of Deeds was correctly ordered to cancel Marasigan’s title and issue a new one in Marron’s name.