G.R. No. L-6609, December 2, 1911
FELIPE DE GUZMAN, petitioner-appellant, vs. MANUEL DE SANTOS Y CABRERA, opponent-appellee.

FACTS

Felipe de Guzman filed a petition for land registration covering a lot in Tondo, Manila. Manuel de Santos opposed, claiming that a portion of the land (154 square meters) described in Guzman’s petition overlapped with his own registered property. The Court of Land Registration sustained Santos’ opposition, finding that Guzman’s southern boundary had encroached upon Santos’ land. Guzman appealed, arguing that his registered title and supporting documents covered the disputed area.

ISSUE

Whether the disputed strip of land is included within the property covered by Felipe de Guzman’s registered title and supporting documents.

RULING

Yes. The Supreme Court reversed the lower court’s decision. It held that the discrepancies in the old deeds describing Guzman’s property were due to approximations and lack of scientific accuracy at the time they were made, and that these documents essentially referred to the same plot. The Court found that the description relied upon by the lower court (from an old document by Palanca) was uncertain, confusing, and evidently erroneous. Guzman’s registered title, which was supported by the history of the property as recorded, covered the land in his petition. The oral testimony presented by Santos was insufficient to overcome Guzman’s registered title. The Court ordered the registration of the disputed land in the name of Felipe de Guzman.