Doria v. Luna
REITERATIONFacts
The Antecedents: Arcadia Doria owned three lots which she leased to petitioner Ernesto Doria for seven crop years, starting 1973-1974 to 1979-1980. Arcadia Doria also leased the same lots to Angelina Bedonia on January 10, 1973, for four agricultural years, covering crop years 1973 to January 1976, with a down payment made. On July 24, 1975, Arcadia Doria sold the property to respondent Manuel Oximer, with the condition that Oximer would take possession only after the expiration of the lease with Angelina Bedonia. On August 25, 1975, petitioner Doria had his lease contract annotated at the back of the certificates of title. On November 26, 1976, Manuel Oximer registered the deed of sale, and new transfer certificates of title were issued in his name, which included the annotations of Doria's lease contract. Procedural History: Petitioner Doria filed a complaint for specific performance with damages against Arcadia Doria, later amended to include Angelina Bedonia and Manuel Oximer as defendants. Arcadia Doria alleged Doria's failure to pay rentals as reason for non-delivery. Manuel Oximer claimed he bought the properties in good faith and for value, unaware of Doria's lease, and asserted Doria had no cause of action against him. The trial court dismissed the complaint against Manuel Oximer, ruling that the lease was not binding upon third persons as it was not recorded at the time of the sale to Oximer. The Petition: Petitioner Doria filed a petition for certiorari seeking to annul the order of dismissal, declare a valid cause of action against Oximer, and compel the respondent judge to try the case on the merits.
Issue(s)
Whether the respondent judge committed a grave abuse of discretion in dismissing the amended complaint against respondent Manuel Oximer; and whether a petition for certiorari is the proper remedy to assail the order of dismissal. Whether the lease contract of the petitioner, not having been annotated at the time of the sale to respondent Manuel Oximer, is binding upon the latter as a third person.
Ruling
The petition is dismissed for lack of merit. The order of dismissal against respondent Manuel Oximer is upheld.
Ratio Decidendi
On the propriety of certiorari and grave abuse of discretion: The Court reiterated that certiorari is an extraordinary remedy that cannot be used as a substitute for an appeal. The petitioner's recourse was to appeal the order of dismissal to the Court of Appeals. Certiorari is only available when the lower court acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack of jurisdiction, and there is no plain, speedy, and adequate remedy in the ordinary course of law. In this case, the dismissal of the complaint was an error that could have been rectified through an appeal. On the binding effect of the unannotated lease contract on third persons: The Court affirmed the ruling of the trial court that unless a lease is recorded, it shall not be binding upon third persons. As Oximer was a third person who acquired the property for value and without notice of the unannotated lease at the time of the sale, the lease contract was not binding upon him. Registration is the operative act that binds third parties to transactions affecting registered land. The subsequent registration of the deed of sale in Oximer's name did not retroactively make the unannotated lease binding on him at the time of his purchase. The Court underscored the importance of annotation on the certificate of title to protect the rights of lessees against subsequent purchasers of the property.
Main Doctrine
A petition for certiorari cannot be a substitute for an appeal; the petitioner should have appealed the challenged order of dismissal to the proper appellate court where alleged errors of fact and law can be corrected.