GR 103558; (November, 1992) (Digest)
G.R. No. 103558 November 17, 1992
METROPOLITAN WATERWORKS AND SEWERAGE SYSTEM, petitioner, vs. THE COURT OF APPEALS, JOSE P. SAMONTE, ET. AL., respondents.
FACTS
Jose B. Dimson was the registered owner of a parcel of land in Balintawak, Kalookan City, covered by TCT No. C-15167 issued on June 8, 1978. This land was originally part of Lot 28 of the Maysilo Estate covered by OCT No. 994 registered on April 19, 1917. Dimson acquired his title through a Deed of Transfer and Conveyance from Bartolome Rivera, an heir of Maria Concepcion Vidal, one of the original owners of OCT No. 994, which was confirmed by court orders in related partition proceedings. Dimson subsequently sold portions of this land to Jose P. Samonte and Francisco C. Isulat. The Metropolitan Waterworks and Sewerage System (MWSS) claimed ownership over the same parcels, asserting it was the registered owner of Lots 2693 and 2695 covered by TCT No. 41028 issued on July 29, 1940, which was derived from a cadastral survey and from OCT No. 994 dated May 3, 1917. MWSS filed and won an ejectment case against Dimson, et al. Subsequently, Dimson and Samonte filed a complaint for quieting of title. The Regional Trial Court ruled in favor of Dimson and Samonte, declaring MWSS’s title void and ordering its cancellation. The Court of Appeals affirmed this decision.
ISSUE
In case of overlapping titles, which title should prevail?
RULING
The Supreme Court ruled in favor of the private respondents (Dimson, et al.). The Court held that although MWSS’s TCT No. 41028 was issued earlier (1940) than Dimson’s TCT No. C-15167 (1978), the decisive factor is the priority of the original certificate of title from which they were derived. Private respondents’ title was derived from OCT No. 994 registered on April 19, 1917, while petitioner’s title, though also purportedly derived from OCT No. 994, was based on a registration dated May 3, 1917. Applying the principle that where two certificates purport to include the same land, the earlier in date prevails, the April 19, 1917 OCT prevails. Furthermore, the Court cited jurisprudence stating that a cadastral court has no jurisdiction to decree again the registration of land already decreed in an earlier land registration case, and such a second decree is null and void. Therefore, the subsequent registration of the same land on May 3, 1917 was invalid. The decision of the Court of Appeals was affirmed.