Lis Pendens

The filing of a notice of lis pendens has a dual effect: (1) to keep the property subject matter of the litigation within the power of the court until the entry of the final judgment in order to prevent the defeat of the final judgment by successive alienations; and (2) to bind a purchaser, bona fide or otherwise, of the property subject of the litigation to the judgment that the court will subsequently promulgate.

Thus, a notice of lis pendens is only valid and effective when it affects title over or right of possession of a real property.

In this case, it cannot be denied that Civil Case No. 67381, which RAM, predecessor-in-interest of petitioner, instituted against Zeñarosa was for collection of sum of money with damages – a purely personal action. Hence, the notice of lis pendens in favor of RAM annotated on the cancelled TCT No. 170213 and carried over to Tan's TCT No. 10206 conferred upon it no rights over the subject property and, as a necessary consequence, upon petitioner, its successor-in-interest (Vashdeo Gagoomal Vs. Spouses Ramon and Natividad Villacorta, G.R. No. 192813. January 18, 2012).