Heirs of Maria Marasigan vs. Intermediate Appellate Court

The Court held that a purchaser of registered land who takes title with a notice of lis pendens annotated thereon is bound by the outcome of the pending litigation. The governing principle is that a notice of lis pendens serves as constructive notice to the whole world that any acquisition of the property is subject to the court's final judgment in the case.

Maria Marron filed Civil Case No. 97479 against spouses Felicisimo Bazar and Fe Springael-Bazar to compel the execution of a deed of sale for a residential lot covered by TCT No. 100612. While the case was pending, Marron caused the annotation of a notice of lis pendens on the title. A judgment was rendered in Marron's favor, which became final and executory. However, prior to the judgment but after the lis pendens was annotated, the Bazar spouses sold the same property to Maria Marasigan via a deed executed in 1974 but registered only in 1977, resulting in the issuance of a new title (TCT No. 126056) in Marasigan's name, which carried over the lis pendens annotation.

• On April 24, 1975, Maria Marron filed Civil Case No. 97479 against the Bazar spouses to compel the sale of a lot covered by TCT No. 100612.
• On January 27, 1976, Marron caused the annotation of a notice of lis pendens on TCT No. 100612.
• On February 24, 1976, the CFI rendered judgment in favor of Marron. The decision became final and executory on June 11, 1976.
• On December 18, 1974, the Bazar spouses executed a deed of absolute sale over the same property in favor of Maria Marasigan. This deed was registered on July 5, 1977, leading to the cancellation of TCT No. 100612 and the issuance of TCT No. 126056 in Marasigan's name. The lis pendens was carried over to the new title.
• The Bazar spouses' petition for relief from the 1976 judgment was filed on May 26, 1977.

• Petitioners argued that Marron's right of action in Civil Case No. 97479 had prescribed and was barred by laches.
• They contended that Marron abandoned her rights under the 1976 judgment by filing subsequent cases (L.R.C. Case No. 7680 and Civil Case No. 126378).
• They asserted that the 1976 judgment never became final and executory due to the pending petition for relief.
• They challenged the jurisdiction of the trial courts in the subsequent cases and over the persons of the Bazar spouses in the original case.
• They argued that the deed of sale executed by the Deputy Clerk of Court on behalf of the Bazar spouses was invalid.

• Respondent Marron countered that the lis pendens annotation bound Marasigan to the outcome of the litigation.
• She maintained that the 1976 judgment became final and executory and that the petition for relief was filed out of time.
• She argued that the registration of Marasigan's purchase occurred after the lis pendens was annotated, making it subject to the litigation's result.

• Procedural Issues: Whether the petition for relief from judgment filed by the Bazar spouses was timely, thereby affecting the finality of the 1976 decision.
• Substantive Issues: Whether a purchaser of registered land (Maria Marasigan) who registers her title after a notice of lis pendens has been annotated acquires rights superior to the party (Maria Marron) in whose favor the lis pendens was annotated and who ultimately won the underlying litigation.

• Procedural: The Court found that the Bazar spouses' petition for relief from judgment was filed beyond the reglementary periods prescribed by Rule 38, Section 3 of the Revised Rules of Court. The 60-day period from knowledge of the judgment and the 6-month period from its entry had both lapsed. Consequently, the 1976 judgment was final and executory.
• Substantive: The Court ruled that the notice of lis pendens constituted constructive notice to the whole world. Since Maria Marasigan registered her deed of sale after the annotation of the lis pendens, she was bound by the outcome of the litigation. The Court affirmed the appellate court's decision ordering the cancellation of Marasigan's title and the issuance of a new title in Marron's name.

• Doctrine of Lis Pendens — This doctrine holds that a pending litigation concerning real property serves as a warning to all persons that any right they may acquire in the property is subject to the event of the suit. The Court applied it to bind Maria Marasigan, who purchased and registered the property with notice of the pending case, to the final judgment in favor of Maria Marron.
• Constructive Notice upon Registration — Pursuant to Section 52 of P.D. 1529 (Property Registration Decree), every conveyance affecting registered land, once registered, is constructive notice to all persons. The Court used this to establish that Marasigan's rights became effective against third parties only upon registration in July 1977, which was after the lis pendens was annotated in January 1976.

• "A notice of lis pendens means that a certain property is involved in a litigation and serves as notice to the whole world that one who buys the same does it at his own risk." — This passage underscores the core consequence of a lis pendens annotation, which the Court applied to defeat Marasigan's claim.
• "... the filing of a notice of lis pendens charges all strangers with a notice of the particular litigation referred to therein and, therefore, any right they may thereafter acquire on the property is subject to the eventuality of the suit." — This quote from Laroza v. Guia was reiterated by the Court to explain the policy rationale behind the doctrine, emphasizing its purpose to prevent judgments from becoming unenforceable due to alienations during litigation.

• Laroza v. Guia, 134 SCRA 341 — Cited to reiterate the established rule and policy rationale of the doctrine of lis pendens, explaining that it prevents parties from rendering a judgment abortive through successive alienations.
• Rivera v. Tirona, et al., 109 Phil. 505 — Cited for the principle that a purchaser pendente lite is bound by the judgment against their vendor.
• The Director of Lands, et al. v. Reyes, 68 SCRA 177 — Cited to establish the duty of the Register of Deeds to carry over a notice of lis pendens on new titles and the liability for failing to do so.
• Domingo v. Dela Cruz, 23 SCRA 1121 and Dirige v. Biranya, 17 SCRA 840 — Cited in the computation of the periods for filing a petition for relief from judgment.

• Section 52, Presidential Decree No. 1529 (Property Registration Decree) — Provides that every conveyance affecting registered land, if registered, is constructive notice to all persons from the time of registration. The Court relied on this to determine when Marasigan's purchase became effective against third parties.
• Section 3, Rule 38 of the Revised Rules of Court — Prescribes the periods for filing a petition for relief from judgment (60 days from knowledge and 6 months from entry). The Court used this to find the Bazar spouses' petition was filed out of time.
• Rule 9, Section 2 of the Revised Rules of Court — Stated that defenses not raised in a motion to dismiss or in the answer are deemed waived. The Court applied this to bar the petitioners from raising prescription, laches, and lack of jurisdiction for the first time on appeal.