Valderama v. Arguelles
REITERATIONFacts
The Antecedents: Respondents Sonia and Lorna Arguelles purchased a parcel of land from Conchita Amongo Francia, the registered owner, and obtained a Transfer Certificate of Title (TCT) No. 266311 in their names. Subsequently, Conchita filed an affidavit of adverse claim which was annotated on the title. After Conchita's death, her sisters, Lourdes Valderama (petitioner) and Tarcila Lopez, opposed the respondents' petition to cancel the adverse claim, asserting that the sale was simulated and that Conchita retained possession and paid taxes. Later, respondents filed a separate civil case for recovery of ownership and possession of the property. Procedural History: Respondents filed a petition to cancel the adverse claim with the Regional Trial Court (RTC). In response, petitioner and Tarcila filed an opposition. Subsequently, respondents filed a complaint for recovery of ownership and possession, leading petitioner and Tarcila to file a notice of lis pendens. Relying on the filing of the notice of lis pendens, respondents moved for the cancellation of the adverse claim. The RTC granted the cancellation, reasoning that the notice of lis pendens rendered the issue moot and academic, while leaving the ownership and possession issues to the other pending civil case. The Court of Appeals (CA) affirmed the RTC's decision, dismissing the appeal for raising a pure question of law. The CA also found no error in the cancellation of the adverse claim, citing Villaflor v. Juezan. The Petition: Petitioner Lourdes Valderama filed a petition for review under Rule 45 of the Rules of Court, assailing the CA's decision. She argued that the CA erred in dismissing her appeal for raising a pure question of law, contending that factual issues were involved. Petitioner also argued that the ruling in Villaflor v. Juezan was inapplicable to the present case and that the annotation of a notice of lis pendens does not automatically warrant the cancellation of an adverse claim. The core issue presented to the Supreme Court was whether the subsequent annotation of a notice of lis pendens on a certificate of title renders a petition for the cancellation of an adverse claim on the same title moot and academic.
Issue(s)
Whether the appeal filed before the CA involved a pure question of law. Whether the ruling of the Supreme Court in Villaflor v. Juezan is inapplicable to this case. Whether an adverse claim annotated on a title may be cancelled merely because a notice of lis pendens was subsequently annotated on the same title.
Ruling
The petition is GRANTED. The Resolutions dated April 11, 2014 and July 31, 2014 of the Regional Trial Court (RTC) in Case No. P-09-499 LRC REC. No. 2400, ordering the cancellation of the Notice of Adverse Claim made as Entry No. 8957/Vol. 132/T-266311, Registry of Deeds of Manila are SET ASIDE and respondents Sonia Arguelles and Lorna Arguelles's petition for cancellation DISMISSED.
Ratio Decidendi
On the issue of whether the appeal before the CA involved a pure question of law: The Court held that the CA did not err in dismissing the appeal for raising a pure question of law. A question of law arises when there is doubt as to what the law is on a certain state of facts, while a question of fact arises when doubt pertains to the truth or falsity of alleged facts. The resolution of a question of law does not require an examination of the probative value of evidence but relies solely on the law itself. In this case, the essential facts were not disputed, and the core issue was the applicability of a legal ruling (Villaflor v. Juezan) to the given facts, which is a question of law. The Court reiterated that the determination of whether an appeal involves only questions of law or both law and fact is best left to the appellate court, and doubts are resolved in its favor unless it commits grave abuse of discretion. On the applicability of Villaflor v. Juezan: The Court ruled that Villaflor v. Juezan is not applicable to the present case due to a different factual milieu. While Villaflor involved a similar issue, its ruling was significantly influenced by the fact that the related civil case subject of the notice of lis pendens had already been terminated and attained finality. In contrast, the civil case filed by the respondents in the present case was still pending before the RTC. The Court emphasized that the termination of the related case was a material factor in Villaflor, making its ruling inapplicable when the related case is still ongoing. On whether a notice of lis pendens justifies the cancellation of an adverse claim: The Court held that a subsequent annotation of a notice of lis pendens does not automatically render a petition for cancellation of an adverse claim moot and academic. The Court distinguished between an adverse claim and a notice of lis pendens, noting that an adverse claim requires a court hearing to determine its validity before it can be cancelled, as mandated by Section 70 of P.D. 1529. Conversely, a notice of lis pendens is a mere incident of an action, does not create a right or lien, and may be cancelled without a court hearing. The Court found the reasoning in Paz Ty Sin Tei v. Jose Lee Dy Piao more in accordance with fair play and justice, stating that the institution of an action and annotation of a notice of lis pendens do not invalidate a prior adverse claim. The Court concluded that the RTC erred in ordering the cancellation of the adverse claim solely based on the subsequent notice of lis pendens, as this would leave the adverse claimant without a remedy to protect their rights.
Main Doctrine
A subsequent annotation of a notice of lis pendens on a certificate of title does not automatically render a petition for cancellation of an adverse claim on the same title moot and academic, as the validity of an adverse claim requires a court hearing, unlike a notice of lis pendens which may be cancelled without one.