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    Laroza vs. Guia

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    Ildefonso Hernaez
    Francisco Guia sold land to Laroza that was subject to ongoing litigation regarding ownership with Donaldo Guia. The court previously ruled the land belonged to Donaldo. Laroza filed a new case to assert ownership, but the Supreme Court held that due to the doctrine of lis pendens, Laroza took a risk in buying the land before the prior case was resolved, and therefore had no legal claim over the property. The court also found the case was barred by res judicata as the central issue of ownership had already been decided. The petition was dismissed.

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    Laroza vs. Guia

    Uploaded by

    Ildefonso Hernaez
    212 views1 page
    Francisco Guia sold land to Laroza that was subject to ongoing litigation regarding ownership with Donaldo Guia. The court previously ruled the land belonged to Donaldo. Laroza filed a new case to assert ownership, but the Supreme Court held that due to the doctrine of lis pendens, Laroza took a risk in buying the land before the prior case was resolved, and therefore had no legal claim over the property. The court also found the case was barred by res judicata as the central issue of ownership had already been decided. The petition was dismissed.

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    Sales case digest

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    Francisco Guia sold land to Laroza that was subject to ongoing litigation regarding ownership with Donaldo Guia. The court previously ruled the land belonged to Donaldo. Laroza filed a new case to assert ownership, but the Supreme Court held that due to the doctrine of lis pendens, Laroza took a risk in buying the land before the prior case was resolved, and therefore had no legal claim over the property. The court also found the case was barred by res judicata as the central issue of ownership had already been decided. The petition was dismissed.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    212 views1 page

    Laroza vs. Guia

    Uploaded by

    Ildefonso Hernaez
    Francisco Guia sold land to Laroza that was subject to ongoing litigation regarding ownership with Donaldo Guia. The court previously ruled the land belonged to Donaldo. Laroza filed a new case to assert ownership, but the Supreme Court held that due to the doctrine of lis pendens, Laroza took a risk in buying the land before the prior case was resolved, and therefore had no legal claim over the property. The court also found the case was barred by res judicata as the central issue of ownership had already been decided. The petition was dismissed.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    60 LAROZA vs.

    GUIA
    G.R. No. L-45252 | 31 Jan 1985 | Relova, J. ISSUES/HOLDING/RATIO:
    1. W/N PET are the real owners of the land -- NO
    SUMMARY: Francisco Guia sold a parcel of land to Laroza, w/c remained a subject ● The record shows that long before PET purchased the property, a notice of
    matter of litigation in the former’s case of partition against Donaldo Guia. CFI ruled lis pendens had already been registered with the Office of the Register of
    that the lands were the property of Donaldo, and so he surveyed and partitioned the Deeds of San Pablo
    same. Laroza, who remained in possession of the lands since the sale, filed the ○ See entire doctrine
    present case. SC held that since Francisco lost in the partition case, Laroza has no ● PET thus took the risk that if their predecessor-in-interest, Francisco, loses in
    right to the property. Civil Case SP-488, PET would lose their right over the property
    ○ Francisco did lose the civil case
    DOCTRINE: ○ PET therefore has no right to the property
    ● Lis pendens = a notice of pending litigation and a warning to the whole world
    that whoever buys the property annotated does so at his own risk 2. W/N the CFI erred in dismissing the complaint based on res judicata – NO
    ● This doctrine is founded on public policy and necessity ● PET argues that there is no identity of causes of action
    ○ Purpose is to keep the subject matter of litigation within the power ○ The present case is an action to quiet title
    of the Court until final judgement ○ Civil Case SP-488 is one of filiation and partition
    ○ Aim is to avoid successive alienations pending litigation which ● SC disagrees: there is res judicata since there is an identity of the causes of
    renders the judgment therein abortive and impossible of execution action
    ○ Both cases essential boil down to a question of ownership of the
    FACTS: land
    ● [Antecedent Fact] 1966 CFI Laguna’s Decision in Civil Case SP-488: Donaldo
    Guia argued he is the co-owner of the land involved in the present case; RULING:
    Francisco Guia (the one who sold the lands to Petitioner Laroza) argued that Petition is dismissed.
    he is the sole owner
    ○ Francisco lost; Donaldo was adjudged as the owner of the lands
    (they were his share in the inheritance)
    ● Years after, Petitioner Laroza insists that he has been in continuous
    possession of the land since their purchase of the same in good faith and for
    valuable considerations from Francisco
    ○ However, Donaldo intruded upon the peaceful possession by
    attempting to survey the land and partition the same, pursuant to
    Civil Case SP-488
    ● PET filed an action to quiet title against Donaldo regarding such parcel of land
    in San Pablo at CFI Laguna
    ○ Donaldo filed a motion to dismiss stating the PET has no cause of
    action; argues that the land in question had already been the subject
    of a final and executory judgment in Civil Case SP-488
    ○ CFI Laguna dismissed the complaint of PET based on res judicata
    ● PET appealed to CA
    ○ CA forwarded the case to the SC because “no factual issue is
    involved” and the “issues raised are purely legal questions beyond its
    jurisdiction”
    ● Hence, this petition

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