G.R. No. 210446 APRIL 18, 2018
ANGELICA G. CRUZ, ANNA MARIE KUDO, ALBERT G. CRUZ and ARTURO G. CRUZ, Petitioners vs MARYLOU TOLENTINO and the Office of the Register of Deeds of Mandaluyong City, Respondents

FACTS

Alfredo S. Cruz was the registered owner of two parcels of land. He executed a Special Power of Attorney (SPA) authorizing his wife, Purificacion, to sell the properties. Alfredo died in 1985. In 1992, two Deeds of Absolute Sale over the properties were executed in favor of respondent Marylou Tolentino—one dated July 9, 1992, purportedly signed by Alfredo, and another dated December 1, 1992, executed by Purificacion under the SPA. Titles were subsequently issued to Tolentino. In 1999, Tolentino filed a complaint (Civil Case No. MC 99-843) against Purificacion and Alfredo’s heirs, seeking to validate the sale concerning Purificacion’s share and to collect the value of the heirs’ shares.
Subsequently, in 2000, the heirs of Alfredo, herein petitioners, filed a separate complaint (Civil Case No. MC00-1300) against Tolentino, Purificacion, and the Register of Deeds. They sought the annulment of the December 1992 sale, cancellation of Tolentino’s titles, and damages, arguing the SA was extinguished by Alfredo’s death, rendering the sale void. Tolentino moved to dismiss the heirs’ complaint, invoking litis pendentia due to her prior pending case.

ISSUE

Whether the trial court correctly dismissed the petitioners’ complaint on the ground of litis pendentia.

RULING

Yes. The Supreme Court affirmed the dismissal based on litis pendentia. For litis pendentia to apply, the following requisites must concur: (1) identity of parties, or at least such parties as represent the same interests in both actions; (2) identity of rights asserted and relief prayed for, the relief being founded on the same facts; and (3) identity of the two cases such that a judgment in one would amount to res judicata in the other. All requisites were present. The parties in both suits were substantially identical, with Tolentino as plaintiff in the first case and defendant in the second, and the Cruz heirs as defendants in the first and plaintiffs in the second. The rights asserted and reliefs sought revolved around the validity of the same sale and the consequent titles over the identical properties. The core issue in both cases was the validity of the conveyance from Purificacion to Tolentino. A final judgment in the first case, which sought to validate the sale and collect the property’s value from the heirs, would constitute res judicata and bar the second action for annulment. The Court emphasized that the principle of litis pendentia aims to prevent multiplicity of suits, protect parties from vexatious litigation, and avoid conflicting judgments. Since Tolentino’s case was filed earlier and remained pending, the subsequent complaint by the heirs was correctly dismissed.