GR 229408; (November, 2020) (Digest)
G.R. No. 229408 , November 09, 2020
CENTRAL REALTY AND DEVELOPMENT CORPORATION, PETITIONER, VS. SOLAR RESOURCES, INC. AND THE REGISTER OF DEEDS OF THE CITY OF MANILA, RESPONDENTS.
FACTS
Petitioner Central Realty and Development Corporation (Central) is the registered owner of a parcel of land in Binondo, Manila covered by TCT No. 198996. In May 2010, Dolores V. Molina annotated a notice of adverse claim on the title, alleging a 1993 sale of the property to her by Central. Central filed a petition for cancellation of this adverse claim (Civil Case No. P-11-726), which was granted by the RTC, Branch 4, in a Decision dated April 11, 2014. The court ordered the cancellation, finding Central had proven no sale occurred and that it remained the owner.
Subsequently, on December 18, 2013, respondent Solar Resources, Inc. (Solar) purchased the property from Molina. After the RTC, Branch 4, ordered the cancellation of Molina’s claim, Solar annotated its own notice of adverse claim on the same title in June 2014. Central then filed a new petition (Civil Case No. P-14-0163) before RTC, Branch 16, seeking the cancellation of Solar’s adverse claim. The RTC, Branch 16, granted Central’s motion for summary judgment and ordered the cancellation. Solar appealed to the Court of Appeals (CA).
ISSUE
Whether the Regional Trial Court, Branch 16, correctly granted summary judgment ordering the cancellation of Solar Resources, Inc.’s adverse claim.
RULING
No, the Supreme Court reversed the grant of summary judgment and remanded the case. Summary judgment is only proper when there is no genuine issue as to any material fact. Here, the Court found the existence of genuine factual issues precluding summary adjudication. Specifically, the validity of Solar’s adverse claim and its right to annotation depended on resolving the underlying issue of ownership, which was inextricably linked to the pending case for specific performance filed by Molina (and where Solar sought substitution) in another branch (Civil Case No. 13-130626). The resolution of whether Molina had a valid claim to sell to Solar is a contentious factual matter central to both cases.
The legal logic is that an adverse claim under Section 70 of Presidential Decree No. 1529 is a litigious inscription precisely designed to protect a claimant’s alleged interest in registered land when no other remedy is available. Its cancellation cannot be summarily decreed when the claimant’s alleged interest is the very subject of a separate pending litigation over ownership. Since the two cases involve the same property, related parties, and closely related issues, the Supreme Court ordered the consolidation of Civil Case No. P-14-0163 with the pending specific performance case (Civil Case No. 13-130626) for a joint trial on the merits. This ensures all issues are fully ventilated and adjudicated expeditiously.