G.R. No. L-45252. January 31, 1985.
Timoteo Laroza and Conchita Uri, plaintiffs-appellants, vs. Donaldo Guia, defendant-appellee.

FACTS

Plaintiffs-appellants Timoteo Laroza and Conchita Uri filed an action to quiet title over a parcel of land in San Pablo City. They alleged they purchased the land in good faith from Francisco Guia on June 30, 1973, after reviewing his documents of ownership, including a deed of sale and a deed of donation. They claimed continuous possession until the defendant-appellee, Donaldo Guia, through court-appointed commissioners in a prior case, Civil Case No. SP-488, intruded by attempting to survey and partition the property pursuant to a final decision in that case dated December 29, 1966.
Defendant-appellee moved to dismiss the complaint, asserting that the land was already the subject of a final and executory judgment in Civil Case No. SP-488, which declared him the owner. He argued the action was barred by prior judgment (res judicata). The trial court granted the motion, ruling that the judgment in SP-488 bound the plaintiffs as successors-in-interest to Francisco Guia, the defeated party in that case. The court noted a notice of lis pendens for SP-488 was registered before the plaintiffs’ purchase.

ISSUE

Whether the trial court correctly dismissed the complaint on the grounds of res judicata and due to the notice of lis pendens.

RULING

Yes, the dismissal was proper. The Supreme Court affirmed, holding the action was barred by res judicata and the doctrine of lis pendens. A notice of lis pendens for Civil Case SP-488 was registered before appellants bought the land. Lis pendens serves as a warning that one who buys annotated property does so at his own risk, subject to the litigation’s outcome. Appellants, as purchasers with such notice, assumed the risk of an adverse judgment against their vendor, Francisco Guia. The doctrine prevents successive alienations from rendering a court’s judgment impossible to execute.
Regarding res judicata, appellants argued no identity of causes of action existed, as their suit was to quiet title while SP-488 involved filiation and partition. The Court rejected this, citing National Bank vs. Barreto, which holds that a judgment sweeps away every defense that should have been raised. Both cases fundamentally concerned ownership of the same land: in SP-488, appellee claimed co-ownership by inheritance, while Francisco Guia claimed sole ownership. The final judgment in SP-488 adjudicated ownership, precluding re-litigation. The Court also found that a hearing on the motion to dismiss was held, and the issue of res judicata was properly raised and discussed by appellee, allowing the trial court to rule on it. The appeal was dismissed for lack of merit.