G.R. No. L-39272 May 4, 1988
EUGENIA SALAMAT VDA. DE MEDINA, petitioner, vs. HONORABLE FERNANDO A. CRUZ, as Presiding Judge of Branch XII, Court of First Instance of Rizal, and REMEDIOS MAGBANUA, respondents.

FACTS

This case originated from Civil Case No. C-120, an action for annulment of sale filed by Benedicta Mangahas and Francisco Ramos against Philippine Realty Corporation and Remedios Magbanua concerning Lot 6, Grace Park Subdivision. Mangahas and Ramos had occupied the lot and built houses without the owner’s consent. The trial court dismissed their complaint and ordered them to vacate and surrender possession to Magbanua, a decision affirmed with finality by the Supreme Court. After Magbanua fully paid the installments, a deed of sale was executed and Transfer Certificate of Title No. 52262 was issued in her name. Subsequently, Eugenia Salamat Vda. de Medina purchased the same lot from the Heirs of Don Mariano San Pedro y Esteban and later bought six houses standing on the lot from third parties. When Magbanua moved for a writ of execution and demolition against Mangahas and Ramos, Medina filed a third-party claim, asserting ownership of the houses and the lot.

ISSUE

Whether the writ of demolition issued by the trial court can be enforced against petitioner Eugenia Salamat Vda. de Medina, who was not a party to the original ejectment case but claims ownership of the properties subject to execution.

RULING

The Supreme Court dismissed the petition and affirmed the writ of demolition. The legal logic rests on two key principles. First, while a writ of execution generally binds only parties and their privies to a case, petitioner Medina was deemed a privy to the judgment debtors, Mangahas and Ramos. She derived her claim to the houses through a chain of title originating from them. As a privy, she is subject to the execution proceedings and cannot claim the status of a complete stranger immune from the judgment. Second, and decisively, respondent Magbanua is the registered owner under the Torrens system. A Torrens title serves as conclusive evidence of ownership, and all persons dealing with registered land are charged with notice of what appears on the face of the title. Medina’s claim, based on a separate deed of sale and tax payments, cannot prevail over Magbanua’s indefeasible registered title. Tax payment is not proof of ownership, especially when the land is registered in another’s name. Therefore, the trial court correctly ordered the demolition to enforce the final judgment in favor of the registered owner.