G.R. No. 133805 ; June 29, 2004
AGUSTINA SENO TAN, petitioner, vs. PACITA GANLAG TAN, assisted by her husband, TERESO TAN, respondent.

FACTS

The dispute involves a parcel of land in Mandaue City, Lot 264-G, originally registered under Eustaquio Seno. In 1971, Miguel Seno filed an adverse claim and a complaint for partition against Eustaquio, which resulted in a 1972 RTC decision ordering the co-owners to partition the property, including Lot 264-G. Despite this, Eustaquio sold the lot to Antonio Albano in 1980, who subsequently sold it to respondent Pacita Ganlag Tan later that same year. The Register of Deeds cancelled the original title and issued a new one (TCT No. 15376) in Pacita’s name. Notably, at the time of Pacita’s purchase, the title presented to her bore no annotation of the adverse claim or notice of lis pendens, as a court order had previously directed its cancellation.
In 1990, the heirs of Graciano Seno, including petitioner Agustina Seno Tan, filed a petition to cancel Pacita’s title. In response, Pacita filed a complaint for quieting of title. The Regional Trial Court ruled in favor of Pacita, declaring her the absolute owner as a purchaser in good faith and for value. The court emphasized that the title was clean when she bought it and that she was not a party to the prior partition case, thus not bound by its judgment. The Court of Appeals affirmed the RTC decision with minor modifications regarding damages.

ISSUE

The core issues were: (1) whether the Court of Appeals correctly denied petitioner’s motion for reconsideration for being filed out of time; (2) whether respondent Pacita Ganlag Tan was a purchaser in good faith; and (3) whether the award of nominal damages and litigation expenses was proper.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. On the procedural issue, the Court held that the client is bound by the negligence of her counsel, and strict compliance with procedural rules is mandatory for the orderly administration of justice. On the substantive issues, the Court found them to be factual in nature. In a petition for review under Rule 45, the Court’s jurisdiction is generally limited to reviewing errors of law, not fact.
The factual findings of the trial court, as affirmed by the Court of Appeals, are binding. These findings conclusively established that respondent was an innocent purchaser for value. When she acquired the property from Albano, the Transfer Certificate of Title presented to her was free from any encumbrance or annotation that would cast doubt on its validity. The prior adverse claim had been cancelled by court order prior to the sale. Consequently, she had no legal obligation to investigate beyond the face of the clean title. Not being a party to the earlier partition suit, she was not bound by its judgment. The awards of nominal damages and litigation expenses, as modified by the appellate court, were upheld based on these premises.