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