G.R. No. 133545. July 15, 2005.
RENATO S. SANCHEZ, Petitioner, vs. RODOLFO M. QUINIO and ISMAEL M. QUINIO, Respondents.

FACTS

The core of the dispute is a parcel of land in Parañaque City originally owned by Celia P. Santiago. On July 12, 1979, Santiago sold the property to respondents Rodolfo and Ismael Quinio. The deed was registered, and Transfer Certificate of Title (TCT) No. S-89991 was issued in their name on July 13, 1979. Over thirteen years later, on February 22, 1993, Santiago purportedly executed another deed of absolute sale over the same land in favor of Renato Sanding, who obtained TCT No. 70372. Sanding subsequently sold the property to Romeo Abel (TCT No. 72406), who then sold it to petitioner Renato Sanchez on November 16, 1993. Sanchez secured TCT No. 81125 on May 17, 1994.
The Quinios, discovering the subsequent transactions and construction on their land, filed a complaint for quieting of title and cancellation of titles against Sanchez and the Abels. The Regional Trial Court dismissed the complaint, ruling that Sanchez was an innocent purchaser for value with a better right. The Court of Appeals reversed this decision, quieting the Quinios’ title and ordering the cancellation of the derivative titles and the removal of structures built by Sanchez.

ISSUE

Who, between petitioner Renato Sanchez and respondents Quinio, has a superior right to the subject land?

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the principle of prior registration and the derivative nature of title. Ownership of the land was irrevocably transferred to the Quinios upon the registration of their sale in July 1979. Consequently, Santiago no longer had any transmissible rights over the property when she executed the 1993 deed in favor of Renato Sanding. That second sale was void, and the title issued to Sanding was a nullity.
Applying the settled rule from Margolles v. Court of Appeals, when two certificates of title are issued to different persons for the same land, the earlier in date prevails. The Quinios’ 1979 title is indisputably prior and therefore superior to any title derived from the 1993 transaction. Sanchez, as a subsequent purchaser, cannot acquire rights greater than those of his predecessors-in-interest (Abel and Sanding). Since their titles originated from a void transaction, Sanchez’s claim of being an innocent purchaser for value fails. His title, being traceable to a defective source, must yield to the Quinios’ earlier and valid title. The spring cannot rise higher than its source. The Court thus upheld the cancellation of the derivative titles and the quieting of the Quinios’ ownership.