G.R. No. 27449 , September 10, 1927
CHUA PUA HERMANOS, petitioner-appellant, vs. REGISTER OF DEEDS OF BATANGAS, respondent-appellee.

FACTS

Chua Pua Hermanos (appellant) obtained a money judgment against Jose H. Katigbak in the Court of First Instance (CFI) of Batangas. Prior to judgment, appellant caused a writ of attachment to be levied on a house and lot in Lipa, Batangas, where Katigbak resided. However, the sheriff’s return did not show that a copy of the attachment order was filed with the Register of Deeds as required by law. After judgment, appellant levied execution on the same property, purchased it at a sheriff’s sale, and presented the sheriff’s certificate of sale to the Register of Deeds for registration.

Meanwhile, another creditor, Samuel Murray, Admr., obtained a judgment against Katigbak in the CFI of Manila. Murray levied execution on the same property, purchased it at a sheriff’s sale, and registered his sheriff’s certificate of sale ahead of appellant. The Register of Deeds refused to register appellant’s certificate, citing the prior recorded certificate in favor of Murray. Appellant sought relief from the CFI, which sustained the Register’s refusal. Hence, this appeal.

ISSUE

Whether the Register of Deeds may lawfully refuse to register a sheriff’s certificate of sale over unregistered land solely because a prior sheriff’s certificate of sale concerning the same property, issued to a different judgment creditor, has already been registered.

RULING

NO. The Register of Deeds has a ministerial duty to register sheriff’s certificates of sale involving unregistered land. The registration is merely a means of giving notice to the public and does not confer validity upon the instrument or adjudicate the competing rights of rival claimants.

The Court held that:
1. Appellant’s attachment was ineffectual because the sheriff failed to file a copy of the attachment order with the Register of Deeds as required by Section 429 of the Code of Civil Procedure. Therefore, appellant could not claim a superior lien as an attaching creditor.
2. The duty to register is ministerial. The Register of Deeds does not exercise quasi-judicial power when presented with such instruments. His function is to record them, not to determine their validity or the priority of rights they represent.
3. Prior registration of a rival certificate is not a legal obstacle. The fact that Murray’s certificate was registered first does not justify refusing registration of appellant’s certificate. The registration system for unregistered property is designed for notice, not for titling. The apparent inconsistency between the two certificates does not relieve the Register of his duty to record the later one.
4. Competing claims are for the courts to resolve. The rights of competing judgment creditors must be determined by the courts in appropriate proceedings, not by the Register of Deeds.

The order of the lower court was REVERSED. The Register of Deeds of Batangas was directed to accept and record appellant’s sheriff’s certificate of sale upon payment of the proper fee.