Jamora v. Duran
REITERATIONFacts
The Antecedents: The plaintiff, Dionisia Jamora, purchased a parcel of land from her sister, Salustiana Jamora, on November 4, 1932. Prior to this purchase, on August 20, 1935, the defendants (Dominga Duran and others) had filed a suit against Salustiana Jamora for the recovery of title and possession of the same land, which suit was decided in favor of Salustiana Jamora by the Court of First Instance and affirmed by the Supreme Court in August 1930. Subsequently, on November 20, 1932, the defendants Dominga Duran, Ricardo Duran, Maria Aguirre, and Enrica Soriano filed a claim in Cadastral Case No. 20, alleging ownership of the lot in question through inheritance. A decision was rendered on December 29, 1932, adjudicating the northern portion to Enrica Soriano and the southern portion to Dominga Duran, Ricardo Duran, and Maria Aguirre. A decree of registration (No. 596222) was issued on June 23, 1936. The plaintiff, Dionisia Jamora, filed a motion in the cadastral case on July 10, 1937, seeking revision of the decree and adjudication in her favor, but this was denied due to the lapse of one year from the issuance of the decree. Procedural History: The plaintiff, Dionisia Jamora, filed Civil Case No. 3857 against the defendants for the recovery of title and possession of the land she purchased. In this case, she was declared the owner, and the defendants were ordered to return possession, with the reservation of her right to seek annulment of the decree of registration in Cadastral Record No. 20. The present appeal stems from a decision ordering defendant Gerardo Villasin to execute a deed of conveyance of the southern portion of lot 432 to the plaintiff and directing the cancellation of Transfer Certificate of Title No. 624 and issuance of a new title in the plaintiff's name. The Petition: The defendants-appellants question the trial court's decision ordering Gerardo Villasin to execute a deed of conveyance and the subsequent cancellation and issuance of a new title in favor of the plaintiff. They argue that the plaintiff cannot seek annulment of the decree of registration as more than one year had passed since its issuance.
Issue(s)
Whether the decision in Civil Case No. 3857 constitutes res judicata as to the plaintiff's right to demand a deed of conveyance. Whether the plaintiff is barred from seeking annulment of the decree of registration due to the lapse of one year from its issuance. Whether Gerardo Villasin, as a subsequent purchaser, is a purchaser in good faith.
Ruling
The Supreme Court affirmed the decision of the lower court, ordering the defendant Gerardo Villasin to execute a deed of conveyance of the southern portion of lot 432 in favor of the plaintiff Dionisia Jamora, and directing the Registrar of Deeds to cancel Transfer Certificate of Title No. 624 and issue a new one in the plaintiff's name. The Court held that the defendants, having obtained the decree of registration with knowledge that they were not the owners, could be compelled to convey the land to its true owner.
Ratio Decidendi
On the issue of res judicata and the plaintiff's right to demand conveyance: The Court held that the decision in Civil Case No. 3857, which declared Dionisia Jamora the owner and ordered the defendants to return possession, was not an attempt to reopen the registration proceedings but rather to compel the defendants, who obtained the decree of registration knowing they were not the owners, to convey the property to its rightful owner. The principle of equity and justice dictates that one should not be unjustly enriched at the expense of another. This principle was applied in cases where a person obtains a certificate of title in their name for land belonging to another, with full knowledge of the true owner's rights, and can be compelled to convey the land. On the plaintiff being barred by the lapse of one year from seeking annulment of the decree: The Court clarified that the present case did not seek to reopen the registration proceedings but to compel the defendants to convey the land to the true owner. While the plaintiff's motion for review of the decree was denied due to the lapse of time, this did not preclude her from seeking equitable relief to enforce her ownership against those who obtained the title fraudulently or in bad faith. The Court emphasized that equity and justice prevent unjust enrichment. On whether Gerardo Villasin is a purchaser in good faith: The Court found that Gerardo Villasin acquired the lot in question on December 22, 1937, by virtue of a deed of sale from the defendants. However, a notice of lis pendens was filed by the plaintiff's attorney with the registrar of deeds of Leyte on August 12, 1937, and was noted on the back of the original certificate of title No. 17816. Although not noted on the owner's duplicate, the filing and registration of the notice of lis pendens constituted constructive notice to third persons, including Gerardo Villasin, of the pendency of the litigation. Therefore, his purchase was subject to the outcome of the litigation, and he could not be considered a purchaser in good faith.
Main Doctrine
A purchaser of registered land who acquires title after a notice of lis pendens has been filed and noted on the original certificate of title is deemed to have constructive notice of the pendency of the litigation and takes the property subject to the result thereof, regardless of whether the notice was noted on the owner's duplicate certificate.