ANNOTATION
 
LIS PENDENS: PREVENTING REAL ESTATE
PROPERTIES FROM BEING PURLOINED
 
by
 
MAURICIO C. ULEP*
 
___________________
 
§  1. Meaning of lis pendens, p. 619
§  2. Purpose and essence of lis pendens, p. 620
§  3. Nature of lis pendens, p. 621
§  4. The essence of lis pendens, p. 622
§  5. A notice of lis pendens is founded on public
policy,
p. 624
§  6. Who may file a notice of lis pendens, p. 624
§  7. When to file a notice of lis pendens, p. 624
§  8. Two-fold effects of a notice of lis pendens, p. 624
§  9. Effect if there is no notice of lis pendens, p. 625
§  10. Elements to annotate a notice of lis pendens, p.
626
§  11. Notice of lis pendens is not a lien on property,
p. 626
§  12. Scope of lis pendens, p. 627
§  13. Constructive notice operates from registration
date of notice of lis pendens, p. 627
§  14. A notice of lis pendens may only be cancelled by
the court, p. 628

_______________

*  Former Associate Dean, UE College of Law; Professor of Law; Author

of Law Books.
  
 
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§  15. Grounds for cancellation of notice of lis

pendens, p. 629
§  16. A notice of lis pendens cannot be cancelled by
posting a bond, p. 630
§  17. The court’s power to cancel lis pendens is
exercised only under exceptional circumstances,
p. 630
§  18. Notice of lis pendens is permissible in
guardianship proceedings, p. 631
§  19. Lis pendens and receivership proceedings, p.
631
§  20. Requisites for lis pendens as a ground for
dismissal of a complaint, p. 632
§  21. One who deals with a property subject of lis
pendens cannot invoke the right of a buyer in
good faith, p. 632
§  22. A notice of lis pendens does not preclude the
sale of the property to an adventurous buyer, p.
633
§  23. A notice of lis pendens cannot be cancelled
pending determination of a case. Exception, p. 633
§  24. Significance of a lis pendens, p. 634
§  25. Any decision in a land registration case binds
only the parties unless notice of lis pendens is
recorded in the title, p. 634
§  26. Proceedings connected with the issue on lis
pendens must be liberally construed, p. 635
§  27. Rule on cancellation of lis pendens, p. 636
§  28. A notice of lis pendens cannot be sought as a
principal action for relief, p. 637
§  29. Only the particular property under litigation is
covered by lis pendens, p. 637
§  30. Pencil markings are not an accepted form of
annotating a notice of lis pendens, p. 638
§  31. Instances where the doctrine of lis pendens has
no application, p. 638
§  32. Damages may not be awarded if court orders
cancellation of lis pendens, p. 639
 
  

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§  33. There is no requirement that the right to a

property subject of lis pendens, be proven by the
applicant,
p. 639
§  34. A notice of lis pendens does not suffice to
protect rights over the property, p. 639
§  35. Effect of filing a notice of lis pendens as to third
persons, p. 640
§  36. Where must the annotation of lis pendens be
made,
p. 641
§  37. Expenses for notice of lis pendens is chargeable
against the estate in a probate proceeding, p. 641
§  38. Effect of lis pendens in an unregistered land, p.
641
§  39. What constitutes constructive notice to any
purchaser of a property with lis pendens, p. 642
§  40. Cancellation of lis pendens is discretionary, p.
642
§  41. Lis pendens cannot affect decree of registration
of a land, p. 643
§  42. Lis pendens as a defense, p. 643
§  43. The wife has the right to annotate a notice of
lis pendens on properties alienated by the
husband,
p. 644
§  44. Procedural matters, p. 645
 
___________________
 
§  1. Meaning of lis pendens
 
Lis pendens is a Latin term which literally means a
pending suit or a pending litigation while a notice of lis
pendens is an announcement to the whole world that a
particular real property is in litigation, serving as a
warning that one who acquires an interest over the said
property does so at his own risk, or that he gambles on the
result of the litigation over the said property. It is but a
signal to the intending buyer or
  
 

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mortgagee to take care or beware and to investigate the

prospect or non-prospect of the litigation succeeding before
he forks down his money. (People v. Regional Trial Court of
Manila, 178 SCRA 299 [1989]; Gonzales v. Marmaine
Realty Corporation, 781 SCRA 63 [2016])
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 so at his own risk. (
Rehabilitation Finance Corporation v. Morales, 101 Phil.
171 [1957]. Cited in Heirs of Maria Marasigan v.
Intermediate Appellate Court, 152 SCRA 253 [1987]. See
also Constantino v. Espiritu, 45 SCRA 557 [1972]; Dela
Merced v. Government Service Insurance System (GSIS),
661 SCRA 83 [2011]; Lukang v. Pagbilao Development
Corporation, 718 SCRA 297 [2014])
 
§  2. Purpose and essence of lis pendens
 
The purpose of filing a notice of lis pendens is to charge
strangers with notice of the particular litigation referred to
in the notice; and if the notice is effective, a third person
who acquires the property affected by the lis pendens takes
same subject to the eventuality of the litigation. But when
the adverse right fails in such litigation, the lis pendens
loses its efficacy.
Moreover, the lis pendens annotation, although
considered a “general notice to all the world, x x x it is not
correct to speak of it as a part of the doctrine of notice; the
purchaser pendente lite is affected, not by notice, but
because the law does not allow litigating parties to give to
others, pending the litigation, rights to the property in
dispute so as to prejudice the opposite party. The doctrine
rests upon public policy, not notice. (Tirado v. Sevilla, 188
SCRA 321 [1990]. See also Laroza v. Guia, 134 SCRA 341
[1985])
Lis pendens has been conceived to protect the real rights
of the party causing the registration thereof. (Jamora v.
Duran, et. al., 69 Phil. 3 [1939]; Homeowners Savings and
Loan Bank
  
 
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v. Felonia, 717 SCRA 358 [2014]) It is a notice which will

bind any prospective buyer to the outcome of the civil case
pending before the trial court. (Knecht v. Court of Appeals,
228 SCRA 1 [1993]. See also Bijis v. Court of Appeals, 15
SCRA 157 [1965])
 
x x x          x x x          x x x
 
Moreover:

The annotation of lis pendens is sufficient to protect the rights

of the private respondents for once a notice of lis pendens has
been duly entered, any cancellation or issuance of title of the land
involved as well as any subsequent transaction affecting the
same, would have to be subject to the outcome of the litigation.
The rights of the private respondents are sufficiently protected
since upon the termination of the litigation there can be no risk of
losing the property or any part of it as a result of any conveyance
of the land or any encumbrance that may be made thereon
posterior to the filing of the notice of lis pendens. (Medelo v.
Gorospe, 159 SCRA 248 [1988])

 
§  3. Nature of lis pendens
 
The notice is but an incident in an action, an
extrajudicial one, to be sure. It does not affect the merits
thereof. It is intended merely to constructively advise, or
warn, all people who deal with the property that they so
deal with it at their own risk, and whatever rights they
may acquire in the property in any voluntary transaction
are subject to the results of the action, and may well be
inferior and subordinate to those which may be finally
determined and laid down therein. The cancellation of such
a precautionary notice is therefore also a mere incident in
the action, and may be ordered by the Court having
jurisdiction of it at any given time. And its continuance or
removal — like the continuance or removal of a
preliminary attachment or injunction — is not contingent
on the existence of a final judgment in the action, and
ordinarily has

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no effect on the merits thereof. (Magdalena Homeowners

Association, Inc. v. Court of Appeals, 184 SCRA 325 [1990])
Moreover:

A notice of lis pendens is an announcement to the whole world

that a particular real property is in litigation, serving as a
warning that one who acquires an interest over said property does
so at his own risk, or that he gambles on the result of the
litigation over the said property. 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. Notice of lis pendens has been conceived and more often
than not, availed of, to protect the real rights of the registrant
while the case involving such rights is pending resolution or
decision. With the notice of lis pendens duly recorded, and while it
remains uncancelled, the registrant could rest secure that he
would not lose the property or any part of it during the litigation.
 (Po Lam v. Court of Appeals, 347 SCRA 86 [2000])

 
Lastly:

A notice of lis pendens neither affects the merits of a case nor

create a right or lien — it serves to protect the real rights of a
registrant while the case involving such rights is pending
resolution, and while the notice of lis pendens remains on a
certificate of title, the registrant could rest secure that he would
not lose the property or any part of it during the litigation. (
Vicente v. Avera, 576 SCRA 634 [2009]. See also AFP Mutual
Benefit Assn., Inc. v. Court of Appeals, 327 SCRA 203 [2000])

 
§  4. The essence of lis pendens
 
Sec. 76 of P.D. 1529 provides:  Notice of lis pendens.—No
action to recover possession of real estate, or to quiet title
thereto, or to remove clouds upon the title thereof, or for
par-
 
 
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tition, or other proceedings of any kind in court directly

affecting the title to land or the use or occupation thereof or
the buildings thereon, and no judgment, and no proceeding
to vacate or reverse any judgment, shall have any effect
upon registered land as against persons other than the
parties thereto, unless a memorandum or notice stating the
institution of such action or proceeding and the court
wherein the same is pending, as well as the date of the
institution thereof, together with a reference to the number
of the certificate of title, and an adequate description of the
land affected and the registered owner thereof, shall have
been filed and registered.
Under said law, lis pendens may lie only where there is
an action or proceeding in court, which affects title to, or
possession of real property. In other words, lis pendens is
the jurisdiction, power, or control which the court acquires
over the property involved in the suit pending the
continuance of the action; and until its final judgment
therein, it has for its object the keeping of the subject or res
within the power of the court until the judgment or decree
shall be entered, to make it possible for courts of justice to
give effect to their judgments and decrees. This, in effect, is
the essence of the rule of lis pendens.
When a case is commenced involving any right to land
registered under the Land Registration Law, any decision
therein will bind the parties only, unless a notice of the
pendency of such action is registered on the title of the said
land, in order to bind the whole world as well. Therefore, in
order that a notice of lis pendens may affect the right of a
subsequent purchaser, such notice should be annotated on
the back of the certificate of title. (Dino v. Court of Appeals,
213 SCRA 422 [1992]. See also Felix Gochan & Sons Realty
Corp. v. Cañada, 165 SCRA 207 [1988])
 
 
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§  5.  A notice of lis pendens is founded on public

policy
 
The doctrine of lis pendens is founded upon reason of
public policy and necessity, the purpose of which is to keep
the subject matter of the litigation within the power of the
court until judgment or decree shall have been entered;
otherwise, by successive alienations pending the litigation,
its judgment or decree shall be rendered abortive and
impossible of execution.   Purchasers pendente lite of the
property subject of the litigation after the notice of lis
pendens is inscribed in the Office of the Register of Deeds
are bound by the judgment against their predecessor. They
will be held to have bought the land in bad faith since they
are charged with notice of the existence of the litigation
over the property in question. (Tanchoco v. Aquino, 154
SCRA 1 [1987]. See also Lim v. Vera Cruz, 356 SCRA 386
[2001])
 
§  6. Who may file a notice of lis pendens
 
The following may file a notice of lis pendens:
1.  The plaintiff – at the time of the filing the
complaint;
2.  The defendant – at the time of filing his answer
(when affirmative relief is claimed in such answer); or at
any time afterwards. (Villanueva v. Court of Appeals, 281
SCRA 298 [1997])
 
§  7. When to file a notice of lis pendens
 
A notice of lis pendens must be filed after filing the
complaint or at any time before the decision of the trial
court is rendered.
 
§  8. Two-fold effects of a notice of lis pendens
 
The filing of a notice of lis pendens has a two-fold effect.
 
 
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First, it keeps the subject matter of the litigation within

the power of the court until the entry of the final judgment
to prevent the defeat of the final judgment by successive
alienations.
Second, it binds a purchaser, bona fide or not, of the
land subject of the litigation to the judgment or decree that
the court will promulgate subsequently. However, the filing
of a notice of lis pendens does not create a right or lien that
previously did not exist.
Without a notice of lis pendens, a third party who
acquires the property after relying only on the certificate of
title is a purchaser in good faith. Against such third party,
the supposed rights of a litigant cannot prevail. (Heirs of
Eugenio Lopez, Sr. v. Enriquez, 449 SCRA 173 [2005]. See
also  Romero v. Court of Appeals, 458 SCRA 483 [2005])
Moreover:

The effect of the notice of lis pendens is not to establish an

actual lien on the property affected. All that it does is to give
notice to third persons and to the whole world that any interest
they may acquire in the property pending litigation will be subject
to the eventuality or result of the suit. It follows to reason,
therefore, that the mere failure to state in a public document, as a
notarized deed of sale, the existence of a notice of lis pendens does
not constitute falsification of a public document under Article 172
of the Revised Penal Code. (People v. Regional Trial Court of
Manila, 178 SCRA 299 [1989])

 
§  9. Effect if there is no notice of lis pendens
 
Without a notice of lis pendens, a third party who
acquires the property after relying only on the certificate of
title is a purchaser in good faith. Against such third party,
the supposed rights of a litigant cannot prevail, because the
former is not bound by the property owner’s undertakings
not anno-
 
 
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tated in the transfer certificate of title. (Heirs of Eugenio

Lopez, Sr. v. Enriquez, 449 SCRA 173 [2005])
Likewise, an unrecorded mortgage of registered land has
no legal effect as far as third parties in good faith are
concerned and rights acquired thereunder cannot prevail
against rights based upon properly recorded transactions. (
Manalo v. Young and Sheriff of Rizal, 44 Phil. 261 [1922])
 
§  10. Elements to annotate a notice of lis pendens
 
To annotate a notice of lis pendens, the following
elements must be present:
(a)  The property must be of such character as to be
subject to the rule;
(b)  The court must have jurisdiction both over the
person and the res; and
(c)  The property or res involved must be sufficiently
described in the pleadings. (Villanueva v. Court of Appeals,
281 SCRA 298 [1997])
 
§  11. Notice of lis pendens is not a lien on property
 
Well-settled is the rule that when the property sold is
registered under the Torrens system, registration is the
operative act to convey or affect the land insofar as third
persons are concerned. Thus, a person dealing with
registered land is only charged with notice of the burdens
on the property which are noted on the register or
certificate of title. While it is true that notices of lis
pendens in favor of other persons were earlier inscribed on
the title, these did not have the effect of establishing a lien
or encumbrance on the property affected. Their only
purpose was to give notice to third persons and to the
whole world that any interest they might acquire in the
property pending litigation would be subject to the result of
the suit. (Agricultural and Home Extension Development
Group v. Court of Appeals, 213 SCRA 563 [1992])
 
 
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§  12. Scope of lis pendens

 
Lis pendens applies to suits brought to establish an
equitable estate, interest or right in specific real property
or to enforce any lien, charge or encumbrance against it. (
Viewmaster Construction Corporation v. Maulit, 326 SCRA
821 [2000]; Gochan v. Young, 354 SCRA 207 [2001];
Romero v. Court of Appeals, 458 SCRA 483 [2005])
The annotation of a lis pendens on titles to properties is
not proper in cases wherein the proceedings instituted are
actions in personam. (Atlantic Erectors, Inc. v. Herbal Cove
Realty Corporation, 399 SCRA 409 [2003])
 
§  13. Constructive notice operates from registration
date of notice of lis pendens
 
In one case, the Supreme Court held:

Petitioner filed Civil Case No. Q-91-10071 way back in 1991.

TCT Nos. 108070 and 108071 were issued in Sarte’s name on May
13, 1994; TCT No. 122944 was issued in respondent’s name on
December 21, 1994. Petitioner had enough opportunity to have its
adverse claim and a notice of lis pendens annotated on Sarte’s
title before the latter assigned the property to Evangelista, but it
did not do so. The adverse claim was annotated only on May 4,
1995 and the notice of lis pendens, on May 31, 1995. While a
notice of lis pendens “serves as a warning to a prospective
purchaser or incumbrancer that the particular property is in
litigation; and that he should keep his hands off the same, unless
he intends to gamble on the results of the litigation,” such
constructive notice operates as such from the date of the
registration of the notice of lis pendens, which in this case, was, at
the earliest, on May 4, 1995. (National Housing Authority v.
Evangelista, 458 SCRA 469 [2005])

 
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The importance of a timely annotation of lis pendens

was illustrated by the Supreme Court in another case, to
wit:
 The land described in transfer certificate of title No. 207
formerly belonged to G. G sold the land to A on January 24, 1920.
On the same date, A mortgaged the land to G. On January 26,
1920, the registrar of deeds issued transfer certificate of title No.
279 free from any encumbrance in the name of A. On March 13,
1920, A mortgaged the land to R. On March 19, 1920, G instituted
suit in Manila to rescind the contract. On March 19, 1920, at 9:30
a.m., the mortgage of A in favor of R was noted on certificate of
title No. 279. At 11:11 a.m. of the same day, the registrar of deeds
was advised by telegraph of the pending suit in Manila.   Lis
pendens was received by the registrar of deeds on March 24, 1920.
Subsequently the deed of sale executed by G in favor of A was
rescinded by the Court of First Instance of Manila, and on appeal
the Supreme Court affirmed judgment. Subsequent to March
1920, also, R foreclosed the mortgage, and purchased the property
at public auction, the sale being confirmed by the Court of First
Instance of Tarlac. It is thus noted that G failed to register the
mortgage executed by A in his favor, while R recorded the
mortgage executed by A in her favor. It is further noted that the
lis pendens of G was received at 11:11 a.m. on March 19, 1920.
Held: That R is an innocent purchaser for value and the owner of
the property. (Martinez de Gomez v. Jugo and Lopez de Jesus, 48
Phil. 118 [1925])

 
§  14. A notice of lis pendens may only be cancelled by
the court
 
In an action affecting the title or the right of possession
of real property, the plaintiff and the defendant, when
affirmative relief is claimed in his answer, may record in
the office of the registry of deeds of the province in which
the property is situated notice of the pendency of the
action. Said notice shall contain the names of the parties
and the object of the action
 
 
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or defense, and a description of the property in that

province affected thereby. Only from the time of filing such
notice for record shall a purchaser, or encumbrancer of the
property affected thereby, be deemed to have constructive
notice of the pendency of the action, and only of its
pendency against the parties designated by their real
names.
The notice of lis pendens hereinabove mentioned may be
cancelled only upon order of the court, after proper showing
that the notice is for the purpose of molesting the adverse
party, or that it is not necessary to protect the rights of the
party who caused it to be recorded. (Section 14, Rule 13,
1997 Rules of Civil Procedure)
The cancellation of lis pendens on a mere certification of
case finality by a court personnel does not appear in order.
The rules dictate that cancellation of the notice should be
done with judicial authority. Then, too, by virtue of the
notice of lis pendens, petitioner is bound by the outcome of
the litigation subject of the lis pendens. As a transferee
pendente lite, he stands exactly in the shoes of the
transferor and must respect any judgment or decree which
may be rendered for or against the transferor. (Seveses v.
Court of Appeals, 316 SCRA 605 [1999]; Office of the Court
Administrator v. De Guzman, Jr., 267 SCRA 291 [1997])
 
§  15. Grounds for cancellation of notice of lis
pendens
 
Sec. 14, Rule 13 of the Rules of Court expressly provides
that courts can cancel a notice of lis pendens only on two
grounds: (a) after a proper showing that the notice is for
the purpose of molesting the adverse party; or (b) it is not
necessary to protect the interest of the party who caused it
to be recorded.
Another ground to cancel a notice of lis pendens as
established is, if it is for the purpose of molesting the
adverse party or that it is not necessary to protect the
rights of the party who caused it to be recorded. (
Magdalena Homeowners Asso-
 
 
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ciation, Inc. v. Court of Appeals, 184 SCRA 325 [1990];

Reyes-Mesugas v. Reyes, 616 SCRA 345 [2010]). Thus, a
notice of lis pendens may be ordered cancelled by the court
if the properties involved are subject to the supervision of
the court and the said properties are under custodia legis. (
Vda de. Kilayko v. Tengco, 207 SCRA 600 [1992])
Lastly, lis pendens is not allowed if it is merely an
anticipatory action or more appropriately, an anticipatory
defense against an expected suit — a clever move to steal
the march from the aggrieved party. (Victronics Computers,
Inc. v. RTC, Br. 63, Makati, 217 SCRA 517 [1993])
 
§  16. A notice of lis pendens cannot be cancelled by
posting a bond
 
The law does not authorize a judge to cancel a notice of
lis pendens pending litigation upon the mere filing of a
sufficient bond by the party on whose title said notice is
annotated. (Tan v. Lantin, 142 SCRA 423 [2000]; Yared v.
Ilarde, 337 SCRA 53 [2000]; Lim v. Vera Cruz, 356 SCRA
386 [2001])
 
§  17. The court’s power to cancel lis pendens is
exercised only under exceptional circumstances
 
The trial court’s inherent power to cancel a notice of lis
pendens is exercised only under exceptional circumstances,
such as: where such circumstances are imputable to the
party who caused the annotation; where the litigation was
unduly prolonged to the prejudice of the other party
because of several continuances procured by petitioner;
where the case which is the basis for the lis pendens
notation was dismissed for non prosequitur on the part of
the plaintiff; or where judgment was rendered against the
party who caused such a notation. In such instances, said
notice is deemed ipso facto cancelled. (Fernandez v. Court
of Appeals, 343 SCRA 184 [2000])
 
 
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Thus, a trial court commits grave abuse of discretion in

ordering the cancellation of a notice of lis pendens where
there was no unnecessary delay attributable to plaintiff
and his counsel in the resolution of the main case for
annulment of the land title, especially when the
cancellation was ordered without notice to plaintiff’s
counsel. (Sarmiento v. Ortiz, 10 SCRA 158 [1964])
Likewise, the order directing the cancellation of the
notice of lis pendens should be set aside where it was
granted ex parte and the order dismissing the complaint
had not yet become final. (Nataño v. Esteban, 18 SCRA 481
[1966])
 
§  18. Notice of lis pendens is permissible in
guardianship proceedings
 
A notice of lis pendens is permissible in guardianship
proceedings for it is precautionary measure against
instances wherein the incompetent may dispose of his
properties in favor of persons who may make undue
advantage of the incompetent’s advanced age and weak
mental and physical condition. (Santos v. Dichoso, 84
SCRA 622 [1978]. See also Gonzales v. Ordoñez-Benitez,
181 SCRA 401 [1990])
 
§  19. Lis pendens and receivership proceedings
 
Under Sections 173 and 174 of the Code of Civil
Procedure, the appointment of a receiver lies within the
sound discretion of the court, it not being a matter of strict
right to ask for an obtain it, nor an imperative duty to
grant it when it is sought. It follows from the foregoing that
the judge who has made the appointment may very well set
aside, as was done by the respondent judge, when in his
opinion it is not justified by the facts and circumstances of
the case.
The respondent judge, in acting as he did, was
undoubtedly guided by the consideration that the
properties sought to be placed in the hands of a receiver
were already in the posses-
 
 
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sion of the defendants and the plaintiff himself; that it

would be of no benefit to them to place the properties in the
hands of a receiver inasmuch as in case of lesion, there is
the remedy of collation provided for by the Civil Code; that
the greater part of said properties consists in real estate
which cannot be easily lost; and that the parties could very
well protect their respective rights by merely recording in
the registry of deeds a notice of lis pendens. (Sanson v.
Araneta, 64 Phil. 549 [1937])
 
§  20. Requisites for lis pendens as a ground for
dismissal of a complaint
 
The requisites for lis pendens as a ground for dismissal
of a complaint are: 1) Identity of parties or at least such as
representing the same interests in both actions; 2) Identity
of rights asserted and prayed for, the relief being founded
on the same facts; and 3) The identity in both cases is such
that the judgment that may be rendered in the pending
case, regardless of which party is successful, would amount
to res judicata in the other case. (Salacup v. Maddela, Jr.,
91 SCRA 275 [1979])
 
§  21. One who deals with a property subject of lis
pendens cannot invoke the right of a buyer in
good faith
 
Once annotated upon the original copy, the notice of lis
pendens is “an announcement to the whole world that a
particular real property is in litigation, serving as a
warning that one who acquires an interest over said
property does so at his own risk, or that he gambles on the
result of the litigation over said property.” One who deals
with property subject of a notice of lis pendens cannot
invoke the right of a purchaser in good faith; neither can he
have acquired better rights than those of his predecessor-
in-interest (Constantino v. Espiritu,
 
 
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45 SCRA 557 [1972]). (See also Yu v. Court of Appeals, 251

SCRA 509 [1995])
 
§  22. A notice of lis pendens does not preclude the
sale of the property to an adventurous buyer
 
 A notice of lis pendens only serves to warn a prospective
buyer or encumbrancer that the particular property is
under litigation and that he should avoid dealing with the
same unless he wishes to gamble on the result of the
litigation. It does not however preclude the possibility of
the said property being sold or encumbered to an
adventurous buyer or encumbrancer. (Sasan v. Court of
Appeals, 165 SCRA 711 [2000])
In fact, where the conveyance of the property subject of
the litigation was made after the notice of lis pendens of
said action was inscribed in the office of the Register of
Deeds, the vendees are considered transferees pendente lite
and are bound by the judgment against their predecessor. (
Correa v. Pascual, et al., 99 Phil. 696 [1956])
 
§  23. A notice of lis pendens cannot be cancelled
pending determination of a case. Exception
 
A notice of lis pendens cannot be cancelled while the
action is pending and undetermined. (Director of Lands v.
Reyes, 68 SCRA 177 [1975])
Exception: The proper court has the discretionary power
to cancel it under peculiar circumstances, as for instance,
where the evidence so far presented by the plaintiff does
not bear out the main allegations of his complaint, and
where the continuances of the trial, for which the plaintiff
is responsible, are unnecessarily delaying the
determination of the case to the prejudice of the defendant.
(Baranda v. Gustilo, 165 SCRA 757 [1988]. See also
Victoriano v. Rovira, 55 Phil. 1000 [1930])
 
 
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§  24. Significance of a lis pendens

 
In one case, the Supreme Court held:

The notice of lis pendens in question was annotated on the back

of the certificate of title as a necessary incident of the civil action
to recover the ownership of the property affected by it. The
mortgage executed in favor of petitioner corporation was
annotated on the same title prior to the annotation of the notice of
lis pendens; but when petitioner bought the property as the
highest bidder at the auction sale made as aftermath of the
foreclosure of the mortgage, the title already bore the notice of lis
pendens. Held: While the notice of lis pendens cannot affect
petitioner’s right as mortgagee because the same was annotated
subsequent to the mortgage, yet the said notice affects its right as
purchaser because notice of lis pendens simply means that a
certain property is involved in a litigation and serves as a notice
to the whole world that one who buys the same does not so at his
own risk. Here, petitioner has not only a constructive knowledge
of said litigation but is a party to the case. Hence, it cannot
demand for the cancellation of the said notice until the case is
finally terminated. (Rehabilitation Finance Corp. v. Morales, 101
Phil. 171 [1957], cited in Homeowners Savings and Loan Bank v.
Felonia, 717 SCRA 358, 370 [2014])

 
§  25. Any decision in a land registration case binds
only the parties unless notice of lis pendens is
recorded in the title
 
Sec. 76 of the Property   Registration Law, P.D. 1529
provides: “No action to recover possession of real estate, or
to quiet the title thereto, or to remove clouds upon the title
thereof, or for partition or other proceeding of any kind in
court affecting the title to real estate or the use and
occupation thereof or the buildings thereon, and no
judgment or decree, and no proceeding to vacate or reverse
any judgment
 
 
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or decree, shall have any effect upon registered land as

against persons other than the parties thereto, unless a
memorandum stating the institution of such action or
proceeding and the court wherein the same is pending, and
the date of the institution thereof, containing also a
reference to the number of the certificate of title of the land
affected and the volume and page of the registration book
where it is entered, shall be filed and registered. x x x” This
is the essence of the rule on lis pendens. Therefore, when a
case is commenced involving any right to lands registered
under the Land Registration Law, any decision therein will
bind the parties only, unless a notice of the pendency of
such action is registered on the title of the land, in order to
bind the whole world as well. (Felix Gochan & Sons Realty
Corp. v. Cañada, 165 SCRA 207 [1988])
 
§  26. Proceedings connected with the issue on lis
pendens must be liberally construed
 
In one analogous case, the Supreme Court held:

The court, however, seeing that it is a precept of the Code of

Civil Procedure that “the provisions of this code, and the
proceedings under it, shall be liberally construed, in order to
promote its object and assist the parties in obtaining speedy
justice”; and seeing moreover that it is of vital concern to the
stability of the law that what the res judicata covers be declared
in a single judgment so that it may produce its far-reaching
effects, it is meet that for the sake of justice the case be restored
to the status of answer to the complaint and not shut the door
upon the parties or fail to bring out before the court the true
nature of the action instituted, so that the question of lis pendens
involved in the defense and already raised, which is of capital
importance in the case, may be decided. (Lazo v. Lazo, 22 Phil.
380 [1912])

 
 
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§  27. Rule on cancellation of lis pendens

 
At any time after final judgment in favor of the
defendant, or other disposition of the action such as to
terminate finally all rights of the plaintiff in and to the
land and/or buildings involved, in any case in which a
memorandum or notice of lis pendens has been registered
as provided in the preceding section, the notice of lis
pendens shall be deemed canceled upon the registration of
a certificate of the clerk of court in which the action or
proceeding was pending stating the manner of disposal
thereof. (Sec. 77, P.D. 1529. See also Cunanan v. Jumping
Jap Trading Corporation, 586 SCRA 620 [2009]; J. Casim
Construction Supplies, Inc. v. Registrar of Deeds of Las
Piñas, 622 SCRA 715 [2010])
Under Section 14, Rule 13 of the Rules of Court, a notice
of lis pendens may be cancelled “after proper showing that
the notice is for the purpose of molesting the adverse party,
or that it is not necessary to protect the rights of the party
who caused it to be recorded.”
In the same vein, case law likewise instructs that a
notice of lis pendens may be cancelled in situations where:
a)  There are exceptional circumstances imputable to
the party who caused the annotation;
b)  The litigation was unduly prolonged to the prejudice
of the other party because of several continuances procured
by petitioner;
c)  The case which is the basis for the lis pendens
notation was dismissed for non prosequitor on the part of
the plaintiff; or
d)  Judgment was rendered against the party who
caused such a notation. (Gonzales v. Marmaine Realty
Corporation, 781 SCRA 63 [2016])
 
 
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§  28. A notice of lis pendens cannot be sought as a

principal action for relief
 
A notice of lis pendens is not and cannot be sought as a
principal action for relief. “The notice is but an incident to
an action, an extrajudicial one to be sure. It does not affect
the merits thereof. It is intended merely to constructively
advise, or warn, all people who deal with the property that
they so deal with it at their own risk, and whatever rights
they may acquire in the property in any voluntary
transaction are subject to the results of the action, and may
well be inferior and subordinate to those which may be
finally determined and laid down therein.” The notice of lis
pendens — that real property is involved in an action — is
ordinarily recorded without the intervention of the court
where the action is pending. As a settled rule, notice of lis
pendens may be annotated only where there is an action or
proceeding in court which affects title to or possession of
real property. (AFP Mutual Benefit Association, Inc. v.
Court of Appeals, 327 SCRA 203 [2000])
 
§  29. Only the particular property under litigation is
covered by lis pendens
 
Lis pendens has been conceived to protect the real rights
of the party causing the registration thereof. With the lis
pendens duly recorded, he could rest secure that he would
not lose the property or any part of it. For such notice
serves as a warning to a prospective purchaser or
incumbrancer that the particular property is in litigation,
and that he should keep his hands off the same unless of
course, he intends to gamble on the results of the litigation.
Based on this principle as well as the express provisions of
Sec. 14, Rule 13 of the 1997 Rules of Civil Procedure, as
amended, only the particular property subject of litigation is
covered by the notice of lis pendens. (Lim v. Vera Cruz, 356
SCRA 386 [2001])
 
 
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§  30. Pencil markings are not an accepted form of

annotating a notice of lis pendens
 
Pencil markings are not an accepted from of annotating
a notice of lis pendens. The Court cannot accept the
argument that such pencil annotation can be considered as
a valid annotation of notice of lis pendens, and thus an
effective notice to the whole world as to the status of the
title to the land. The law requires proper annotation, not
“provisional” annotation of a notice of lis pendens. If we
allow provisional annotations as a valid form of annotation
of notice of lis pendens, we would be eroding the very value
of the indefeasibility of the torrens system. (AFP Mutual
Benefit Association, Inc. v. Court of Appeals, 364 SCRA 768
[2001])
 
§  31. Instances where the doctrine of lis pendens has
no application
 
 Notice of lis pendens does not apply under the following
instances:
(1)  Where the case is concerned merely with the
correctness of the denial by the probate court of the motion
for the removal of the special administratrix of the estate
which does not involve the title to or possession of real
properties of the estate. (Garcia v. Vasquez, 32 SCRA 490
[1970])
(2)  The doctrine of lis pendens has no application in the
following cases: a) Preliminary attachments; b) Proceedings
for the probate of wills; c) Levies on execution; d)
Proceedings for administration of estate of deceased
persons; and e) Proceedings in which the only object is the
recovery of a money judgment. (Tongohan v. Court of
Appeals, 447 SCRA 384 [2004]; Gagoomal v. Villacorta, 663
SCRA 444 [2012])
(3)  A notice of lis pendens does not apply to actions
involving title to or any right or shares in a private
nonstock corporation. (MR Holdings, Ltd. v. Bajar, 683
SCRA 336 [2012])
 
 
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§  32. Damages may not be awarded if court orders

cancellation of lis pendens
 
In one case, the Supreme Court held:

Since in the case at bar the plaintiffs have no right whatsoever

to the land involved in the two cases before the court of first
instance, because their claim is barred by a decree of registration
and by the statute of limitations, the partial cancellation of their
notice of lis pendens in one of the said cases — independently of
the circumstances under which said partial cancellation had been
secured — caused them no damage whatsoever and they have no
cause of action therefor against the defendant. (Garcia v. Fenoy, 6
SCRA 486 [1982])

 
§  33. There is no requirement that the right to a
property subject of lis pendens, be proven by the
applicant
  
There is no requirement that the right to or the interest
in the property subject of a lis pendens be proven by the
applicant. The Rule merely requires that an affirmative
relief be claimed. A notation of lis pendens neither affects
the merits of a case nor creates a right or a lien. It merely
protects the applicant’s rights, which will be determined
during the trial. (Alberto v. Court of Appeals, 334 SCRA
756 [2000]; Romero v. Court of Appeals, 458 SCRA 483
[2005])
 
§  34. A notice of lis pendens does not suffice to
protect rights over the property
 
A notice of lis pendens serves as an announcement to the
whole world that a particular real property is in litigation
and as a warning that those who acquire an interest in the
property do so at their own risk — they gamble on the
result of the litigation over it. However, the cancellation of
such notice may be ordered by the court that has
jurisdiction over it at
 
 
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any given time. Its continuance or removal — like the

continuance or the removal of a preliminary attachment or
injunction — is not contingent on the existence of a final
judgment on the action and ordinarily has no effect on the
merits thereof. Thus, the notice of lis pendens does not
suffice to protect herein respondents’ rights over the
property. It does not provide complete and ample
protection. (Los Baños Rural Bank, Inc. v. Africa, 384
SCRA 535 [2002]; Tangohan v. Court of Appeals, 447 SCRA
384 [2004])
 
§  35. Effect of filing a notice of lis pendens as to third
persons
 
The effect of filing notice of lis pendens is to charge the
stranger with notice of the particular litigation referred to
in the notice; and if the notice is effective, a third person
who acquires the property affected by the lis pendens takes
subject to the eventuality of the litigation. But when the
adverse right fails in such litigation, the lis pendens loses
its efficacy. (Atkins, Kroll & Co v. Domingo, 46 Phil. 362
[1924]. See also Po Lam v. Court of Appeals, 347 SCRA 86
[2000])  
Once   a notice of lis pendens has been duly registered,
any cancellation or issuance of the title of the land involved
as well as any subsequent transaction affecting the same,
would have to be subject to the outcome of the litigation. In
other words, upon termination of the litigation there can be
no risk of losing the property or any part thereof as a result
of any conveyance of the land or any encumbrance that
may be made thereon posterior to the filing of the notice of
lis pendens.       (Unionbank of the Philippines v. Court of
Appeals, 311 SCRA 795 [1999])
Moreover:

Transferees of title to land subject to the notice of lis pendens

are bound by the judgment rendered against their predecessors-
in-interest. (Selph v. Vda. de Aguilar, 107 Phil. 443 [1960])

 
 

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§  36. Where must the annotation of lis pendens be

made
 
The annotation of lis pendens is done on the original
certificate of title which is on file with the Register of
Deeds. (Francisco Motors Corporation v. Court of Appeals,
505 SCRA 8 [2006])
It is not required that the annotation of lis pendens be
also inscribed upon the owner’s copy because such copy is
usually unavailable to the registrant. It is normally in the
hands of the adverse party. (Yu v. Court of Appeals, 251
SCRA 509 [1995])
 
§  37. Expenses for notice of lis pendens is chargeable
against the estate in a probate proceeding
 
Where, in order to gather all the assets of the estate and
carry out the provisions of the will of the deceased, the
executor had to institute an action for the annulment of a
deed of donation in favor of a certain person, incurring
expenses for the cost of the transcript of stenographic notes
and the cost of printing a brief in connection with the
annotation of a notice of lis pendens, said expenses are
chargeable against the estate. (Bank of the Philippine
Islands v. Gonzales, 106 Phil. 925 [1960])
 
§  38. Effect of lis pendens in an unregistered land
 
The non-registration of the judgment within 60 days
after the rendition thereof, as required by Section 79 of the
Land Registration Act, does not render the notice of lis
pendens ineffective. Even if it does, the judgment will not
be binding only as against persons other than the parties to
the suit. It is still binding on the parties and their
successors-in-interest.
One who buys land from a person who is not registered
owner is not considered a subsequent purchaser of
registered
 
 

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land who takes the certificate of title for value and in good
faith and who is protected against any encumbrance except
those noted on said certificate. (Rivera, etc. v. Tirona, et al.,
109 Phil. 505 [1960])
 
§  39. What constitutes constructive notice to any
purchaser of a property with lis pendens
 
The filing of the notice of lis pendens in the office of the
registrar of deeds and the notation thereof on the back of
the corresponding original certificate of title is what
constitutes a constructive notice to any purchaser or
vendee of a lien upon the real property in litigation as to
the parties-litigant.   (Jamora v. Duran et al., 69 Phil. 3
[1939])
 
§  40. Cancellation of lis pendens is discretionary
 
 While ordinarily a notice of pendency which has been
filed in a proper case, cannot be cancelled while the action
is pending and undetermined, the proper court has the
discretionary power to cancel it under peculiar
circumstances, as for instance, where the evidence so far
presented by the plaintiff does not bear out the main
allegations of his complaint, and where the continuances of
the trial, for which the plaintiff is responsible, are
unnecessarily delaying the determination of the case to the
prejudice of the defendant. (Municipal of Parañaque v.
Court of First Instance, 70 Phil. 363 [1940])
Moreover:

While notice of lis pendens remains during the pendency of the

action although same may be cancelled under certain
circumstances as where the case is prolonged unnecessarily or for
failure of the plaintiff to introduce evidence bearing out the
allegations of the complaint.

 
 
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It has even been held that a court, in the absence of a

statute, has the inherent power to cancel a lis pendens
notice in a proper case, i.e., after the claim is adjudged
invalid or unmeritorious by the Court, acting either as a
land registration court or one of general jurisdiction while
passing upon a case before it where the subject of the
litigation is the same interest or right which is being
secured by the adverse claim. (Ty Sin Tei v. Lee Dy Piao,
103 Phil. 858 [1958])
The cancellation of a notice of lis pendens, being a mere
incident to an action, may be ordered at any given time by
the court having jurisdiction over it. (Roxas v. Dy, 223
SCRA 643 [1993])
 
§  41. Lis pendens cannot affect decree of registration
of a land
 
The notice of lis pendens filed by the plaintiffs with the
register of deeds cannot affect the decree of registration
issued upon the lands in question, since its object is to
protect the rights which the plaintiffs might have in the
aforesaid lands, against third persons, and it does not
relieve them from the necessity of objecting to the
application for registration filed by the defendant of the
same lands some two years previous to the filing and
recording of said notice of lis pendens for the protection of
their rights. (Valmonte v. Villaroman, 52 Phil. 221 [1928])
Likewise, a notice of lis pendens could only apply to a
property in litigation. An undivided interest over half of a
property which is not under litigation could not be affected.
(Mercado v. Viardo, 5 SCRA 859 [1962])
 
§  42. Lis pendens as a defense
 
In one case, the Supreme Court held:
 
 
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With respect to the defense of lis pendens, these facts are

alleged: First, that on May 10, 1907, the defendant brought suit
against the plaintiff in the Court of First Instance of Nueva Ecija,
for the purpose of obtaining the rescission of this same contract,
on the ground of plaintiff’s noncompliance therewith; and second,
that the plaintiff did not file the present suit against the
defendant until October 1907.

 
By such allegations the defendant endeavored to weaken
plaintiff’s cause of action and prayed for a dismissal of the
complaint; but the court held that neither the answer nor
the evidence appeared to be sufficient to establish this
defense and that, after all, it was not claimed that the suit
was prosecuted to final judgment and, consequently, it
could not serve as a basis for the defense of res adjudicata.
(Kelly Springfield Road Roller Co. v. Sideco, 16 Phil. 345
[1910]. See also Cabillas v. Apduhan, 14 Phil. 213 [1909])
 
§  43. The wife has the right to annotate a notice of
lis pendens on properties alienated by the
husband
 
 Although, under the second paragraph of Article 1419 of
the Civil Code, a widow is entitled to charge against the
husband, in the liquidation of the conjugal estate, the value
of property alienated by the husband in fraud of her rights,
the failure to exercise this right is   no obstacle to the
maintenance by the wife of an action to annul a conveyance
made by the husband without consideration and in fraud of
the rights of the wife, with respect to property which is
assigned to the wife in the judicial liquidation of the estate,
notice of the lis pendens created by the liquidation
proceedings having been noted on the transfer certificate
issued to the grantee. (Gallion v. Gayares, 53 Phil. 43
[1929])
 
 
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§  44. Procedural matters

 
1.  With reference to an innocent purchaser in good
faith, the date of the notice of the pendency of an action is
not that on which the notice was entered on the original
certificate in the office of the registrar but the date on
which such notice was entered on the owner’s duplicate
certificate of title presented by the purchaser. (Pineda v.
Santos, 56 Phil. 583 [1932])
2.  Where the vendor fails to deliver to the vendee the
duplicate certificate of title, the vendee should file
immediately with the Register of Deeds an adverse claim
under Section 110 of Act. 496, as amended. (Junio v. De los
Santos, 132 SCRA 209 [1984])
3.  The lower court’s orders cancelling the notice of lis
pendens as regards certain specified certificates of title
covering a certain hacienda do not amount to abuse of
discretion, especially where the nature of the evidence
introduced by petitioners apparently was not such as to
impart to respondent judge the impression that petitioner’s
cause of action was sufficiently meritorious to warrant a
reconsideration of its first order of cancellation. (
Montelibano v. De la Cruz, 10 SCRA 821 [1964]. See also
Lising v. Plan, 133 SCRA 194 [1984])
4.  Lis pendens is normally interposed as a defense
when another case is pending upon the same cause of
action between the same parties in two complaints. It may
also be interposed even if said claim is set forth by way of a
counterclaim since the latter partakes the nature of a
complaint by the defendant against the plaintiff. (Arceo v.
Oliveros, 134 SCRA 308 [1985])
5.  The desire of a party to annotate a notice of lis
pendens in a civil case becomes moot once said case is
dismissed. (Gosiaco v. Tiu Po, 138 SCRA 448 [1985])
6.  Before cancellation of a notice of lis pendens
annotated on a title, notice to the party who caused it to be
recorded must be made so that he may be given a chance to
be heard
 
 

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and show to the court that the notice is not for the purpose
of molesting the adverse party and that it is necessary to
protect his rights. (Punongbayan v. Pineda, 131 SCRA 496
[1984])
7.  The refusal of a party to lift the notice of lis pendens
does not affect the validity of a compromise agreement. (
Mayuga v. Court of Appeals, 154 SCRA 310 [1987])
8.  The dismissal of a civil case made upon petition of
the defendant by reason of the plaintiff’s failure to appear,
operates as a cancellation of the notation of lis pendens.  (
Lazaro v. Mariano, 59 Phil. 627 [1934])
9.  For lis pendens to be a valid ground for the dismissal
of a case, the other case pending between the same parties
and having the same cause must be a court action. (Puma
Sportschuhfabriken Rudolf Dassler, K.G. v. Intermediate
Appellate Court, 158 SCRA 233 [1988])
10.  It is not required that the annotation of lis pendens
be also inscribed upon the owner’s copy because such copy
is usually unavailable to the registrant. It is normally in
the hands of the adverse party. (Yu v. Court of Appeals, 251
SCRA 509 [1995])
11.  The annotation of a notice lis pendens does not in
any case amount nor can it be considered as equivalent to a
collateral attack of the certificate of title for a parcel of
land. (Lee Tek Sheng v. Court of Appeals, 292 SCRA 544
[1998])
 12.  Denial of a lis pendens by the Register of Deeds can
be appealed en consulta to the Commissioner of Land
Registration. From there, it may further be appealed to the
Court of Appeals. (AFP Mutual Benefit Association, Inc. v.
Court of Appeals, 327 SCRA 203 [2000])
13.  The order of a judge for the cancellation of a notice
of lis pendens is an interference with the business of the
Court of Appeals if the case is already pending before the
latter. (Brizuela v. Mendiola, 335 SCRA 23 [2000])
 
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