Primary Holding

In cases of double registration under the Torrens system, the certificate of title earlier in date prevails over the later one; registered title holders are not obligated to continuously monitor subsequent land registration proceedings to protect their already registered title.

Background

Two owners of adjacent lots in Manila, Legarda and Saleeby, both registered their lands under the Torrens system. A stone wall situated on Legarda's property was mistakenly included in both their initial registration and Saleeby's subsequent registration, leading to conflicting claims over the wall and the land it occupied.

Facts

• 1. Legarda and Saleeby owned adjacent lots in Ermita, Manila, separated by a stone wall situated on Legarda's property.
• 2. Legarda registered their land in 1906 under the Torrens system, with the certificate including the wall.
• 3. Saleeby’s predecessor registered his adjacent land in 1912, and his certificate erroneously also included the same wall.
• 4. Legarda discovered the double registration and sought correction from the Court of Land Registration.
• 5. The lower court denied the petition, arguing Legarda should have opposed Saleeby’s registration.
• 6. The wall was not a joint wall but located entirely on Legarda's land.

Arguments of the Petitioners

• 1. Legarda already had a registered title to their land, including the wall, prior to Saleeby's registration.
• 2. Saleeby’s registration was erroneous in including land already registered under Legarda's name.
• 3. The Torrens system aims to quiet titles and provide security to registered landowners, not to necessitate constant vigilance against potential encroachments in subsequent registration proceedings.
• 4. The earlier registration should prevail to uphold the integrity of the Torrens system.

Arguments of the Respondents

• 1. Saleeby, through his predecessor, argued that Legarda should have opposed their land registration petition in 1912.
• 2. Legarda's failure to oppose Saleeby's registration made the decree binding, and Legarda lost their right to claim the wall.
• 3. The land registration proceeding is judicial and binding on all parties who did not appear to oppose.

Issues

• 1. In cases of double registration under the Torrens system, which certificate of title should prevail?
• 2. Does the failure of the prior registered owner to oppose a subsequent registration proceeding concerning the same land forfeit their rights under their earlier title?
• 3. Is a registered owner obligated to continuously monitor land registration proceedings to protect their existing title?

Ruling

• 1. The Supreme Court ruled in favor of Legarda, holding that the earlier registered title is superior.
• 2. The Court reasoned that the Torrens system's purpose is to quiet titles and provide security, which would be undermined if registered owners had to constantly monitor for subsequent registration attempts.
• 3. The principle of notice inherent in the Torrens system means that Saleeby and his predecessors were constructively notified of Legarda's prior registration.
• 4. The failure of Legarda to oppose Saleeby’s registration did not invalidate their prior registered title, as the decree of registration is not meant to divest rights already secured under a prior registration.
• 5. The court emphasized that allowing subsequent registration to diminish a prior registered title would destroy the security and purpose of the Torrens system.

Doctrines

• 1. Torrens System of Land Registration: A system of land registration whose primary objective is to quiet title to land and to stop forever any question as to its legality. The certificate of title is conclusive evidence of ownership.
• 2. Indefeasibility of Title: Once a title is registered under the Torrens system, it becomes incontrovertible and cannot be defeated by prior claims, subject to limited exceptions like fraud.
• 3. Constructive Notice: Registration in the public registry serves as notice to the whole world. All persons are charged with knowledge of what the record contains, regardless of actual knowledge.
• 4. Priority of Registration: In cases of double registration, the earlier registered title generally prevails.
• 5. Action in Rem: Land registration proceedings are actions in rem, meaning they are directed against the thing itself and bind the whole world.

Key Excerpts

• 1. "The real purpose of that system is to quiet title to land; to put a stop forever to any question of the legality of the title, except claims which were noted at the time of registration, in the certificate, or which may arise subsequent thereto."
• 2. "That being the purpose of the law, it would seem that once a title is registered the owner may rest secure, without the necessity of waiting in the portals of the court, or sitting in the 'mirador de su casa,' to avoid the possibility of losing his land."
• 3. "The title once registered, with very few exceptions, should not thereafter be impugned, altered, changed, modified, enlarged, or diminished, except in some direct proceeding permitted by law. Otherwise all security in registered titles would be lost."
• 4. "The general rule is that in the case of two certificates of title, purporting to include the same land, the earlier in date prevails..."
• 5. "A title once registered can not be defeated, even by an adverse, open, and notorious possession. Registered title under the torrens system can not be defeated by prescription."

Precedents Cited

• 1. Escueta vs. Director of Lands, 16 Phil. Rep., 482: Used to support the judicial nature of land registration under the Torrens system and its binding effect on the whole world (action in rem).
• 2. Grey Alba vs. De la Cruz, 17 Phil. Rep., 49: Also cited to reinforce that land registration is an action in rem.
• 3. Roxas vs. Enriquez, 29 Phil. Rep., 31: Further supports the action in rem nature of land registration.
• 4. Tyler vs. Judges, 175 Mass., 71: Cited as foreign jurisprudence supporting the action in rem nature.
• 5. American Land Co. vs. Zeiss, 219 U. S., 47: Another foreign case cited for the same purpose.
• 6. Oelkers vs. Merry, 2 Q. S. C. R., 193; Miller vs. Davy, 7 N. Z. R., 155; Lloyd vs. May-field, 7 A. L. T. (V.) 48; Stevens vs. Williams, 12 V. L. R., 152; Register of Titles vs. Esperance Land Co., 1 W. A. R., 118: Cited from Hogg's "Australian Torrens System" to support the rule that the earlier certificate of title prevails in double registration.
• 7. Northwestern National Bank vs. Freeman, 171 U. S., 620, 629; Delvin on Real Estate, sections 710, 710 [a]: Cited to support the principle of constructive notice upon proper recording of conveyances.
• 8. Grandin vs. Anderson, 15 Ohio State, 286, 289; Orvis vs. Newell, 17 Conn., 97; Buchanan vs. International Bank, 78 111., 500; Youngs vs. Wilson, 27 N. Y., 351; McCabe vs. Grey, 20 Cal., 509; Montefiore vs. Browne, 7 House of Lords Cases, 341: Further cases cited to support the doctrine of constructive notice.

Statutory and Constitutional Provisions

• 1. Act No. 496 (Land Registration Act): Specifically Sections 38, 46, 55, and 112 are mentioned, dealing with conclusiveness of decree, indefeasibility and innocent purchasers. Section 38 is quoted directly.
• 2. Article 1473 of the Civil Code: Analogously applied regarding priority of registration in cases of double sale of real property under the ordinary registry system.
• 3. Articles 1875 and 606 of the Civil Code & Article 1-875 (likely a typo, should be Art. 1875 again): Mentioned in the context of mortgage registration to illustrate the mandatory nature of public record notice, though not directly applicable to land title registration itself but used for comparative reasoning.
• 4. Section 38 of Act No. 496 is directly quoted in the decision regarding the conclusiveness of the decree of registration.