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ROBERT SAN PEDRO v. WILLY ONG

This case has been cited 4 times or more.

	GR No. 188395 2013-11-20	HEIRS OF LATE FELIX M. BUCTON v. SPS. GONZALO AND TRINIDAD GO PEREZ, J.
While this Court protects the right of the innocent purchaser for value and does not require him to look beyond the certificate of title, this protection is not extended to a purchaser who is not dealing with the registered owner of the land. In case the buyer does not deal with the registered owner of the real property, the law requires that a higher degree of prudence be exercised by the purchaser. As succinctly pointed out in San Pedro v. Ong:[40]
	GR No. 196577 2013-02-25	LAND BANK OF PHILIPPINES v. BARBARA SAMPAGA POBLETE CARPIO, J.
Where the mortgagee acted with haste in granting the mortgage loan and did not ascertain the ownership of the land being mortgaged, as well as the authority of the supposed agent executing the mortgage, it cannot be considered an innocent mortgagee.[39]
	AM No. P-11-2986 2012-06-13	SPS. RAINER TIU AND JENNIFER TIU v. VIRGILIO F. VILLAR MENDOZA, J.
On the questioned substituted service of summons, the Court concurs with the findings of the investigating judge that there was a valid substituted service of summons. As a rule, personal service of summons is preferred as against substituted service. Thus, substituted service can only be resorted to by the process server only if personal service cannot be made promptly. Most importantly, the proof of substituted service of summons must (a) indicate the impossibility of service of summons within a reasonable time; (b) specify the efforts exerted to locate the defendant; and (c) state that the summons was served upon a person of sufficient age and discretion who is residing in the address, or who is in charge of the office or regular place of business, of the defendant. It is likewise required that the pertinent facts proving these circumstances be stated in the proof of service or in the officer's return.[17]
	GR No. 167391 2011-06-08	PHIL-VILLE DEVELOPMENT v. MAXIMO BONIFACIO VILLARAMA, JR., J.
Significantly, an action to quiet title is characterized as a proceeding quasi in rem.[56] In an action quasi in rem, an individual is named a defendant and the purpose of the proceeding is to subject his interests to the obligation or loan burdening the property. Actions quasi in rem deal with the status, ownership or liability of a particular property but which are intended to operate on these questions only as between the particular parties to the proceedings and not to ascertain or cut off the rights or interests of all possible claimants. The judgment therein is binding only upon the parties who joined in the action. [57]