CIVIL PROCEDURE I Hon. Janice L.

Andrade-Udarbe

NAME: DELA CRUZ, MARK LLOYD V.

CASE TITLE& GR.NO: ST. MARY OF THE WOODS SCHOOL, INC. and
MARCIAL P. SORIANO, petitioners, vs. OFFICE OF THE REGISTRY OF
DEEDS OF MAKATI CITY and HILARIO P. SORIANO, Respondents.
G.R. No. 174290
DOCTRINE/TOPIC /ARTICLE RELATED:
The doctrine related to the jurisprudence provided revolves around the
legal principle of lis pendens, which is Latin for "pending litigation." Lis pendens
refers to the jurisdiction, power, or control that a court acquires over property
involved in a lawsuit until a final judgment is rendered. It serves to keep
properties within the jurisdiction of the court until the litigation is resolved and
to alert potential buyers or interested parties that the property is subject to ongoing
legal proceedings. This doctrine is founded on public policy and necessity, aiming
to prevent the defeat of a judgment by subsequent alienation of the property and
to provide notice to the public of the property's status. Lis pendens is essential in
maintaining the integrity of legal proceedings and ensuring that the rights of
parties involved are protected.
FACTS: The case involves a dispute over properties covered by Transfer
Certificates of Title (TCT) Nos. 175209, 220977, and 220978. It began with a
Complaint filed by the private respondent, Hilario, in the Regional Trial Court
(RTC) against SMWSI and others, claiming ownership of the said properties as
part of his inheritance from his late father, Tomas Q. Soriano. The RTC, however,
dismissed Hilario's Complaint on the grounds that it failed to state a cause of
action and that the claim had been paid or extinguished. Hilario appealed the
dismissal to the Court of Appeals (CA). During the pendency of the appeal,
Hilario filed a Motion to Reinstate/Re-annotate Notice of Lis Pendens concerning
the properties in question. The CA granted this motion, citing the necessity to
inform the public about the ongoing litigation and to protect the rights of the
parties involved. SMWSI contested the CA's jurisdiction to entertain the issue of
the notice of lis pendens, but the CA upheld its authority, emphasizing the
importance of maintaining the integrity of the ongoing legal proceedings. SMWSI
then sought recourse with the Supreme Court through a Petition for Certiorari.
However, the Supreme Court dismissed the petition, affirming the CA's rulings.
Throughout the proceedings, various legal issues were raised, including questions
of fact and law, the validity of the notice of lis pendens, and the jurisdiction of

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 CIVIL PROCEDURE I Hon. Janice L. Andrade-Udarbe

the appellate court. Ultimately, the case underscored the significance of lis
pendens in safeguarding the interests of parties involved in property disputes and
ensuring the orderly administration of justice.
ISSUE/S: Whether the Court of Appeals had the authority to entertain the issue
of the notice of lis pendens, the propriety of reinstating/re-annotating the notice,
and whether the filing of the motion to reinstate/re-annotate constituted forum
shopping.
RULING/HELD: Yes. The Court of Appeals had jurisdiction over the issue of
the notice of lis pendens as it was raised in the appeal before them. They found it
necessary to address the validity and reinstatement of the notice considering its
importance in the ongoing litigation and the potential impact on third-party
transactions involving the subject properties. The appellate court's jurisdiction
was upheld to ensure the orderly disposition of the case and to prevent any
interference with the litigation process.

Enverga Law School – Veritas. Integritas. Justitia