G.R. No. 167412 ; February 22, 2006
JUANITA NAVAL, Petitioner, vs. COURT OF APPEALS, JUANITO CAMALLA, JAIME NACION, CONRADO BALILA, ESTER MOYA and PORFIRIA AGUIRRE, Respondents.

FACTS

The case involves a parcel of unregistered land originally owned by Ildefonso Naval. On December 2, 1969, Ildefonso sold the land to Gregorio Galarosa. This deed of sale was registered with the Registry of Deeds of Camarines Sur on December 3, 1969, pursuant to Act No. 3344 . Gregorio subsequently sold portions of the land to the respondents at various dates from 1976 to 1987. The respondents took possession, built improvements, and paid realty taxes.
Petitioner Juanita Naval, Ildefonso’s great-granddaughter, claimed she purchased the same land from Ildefonso in 1972. She was issued an Original Certificate of Title (OCT) for the land on April 1, 1975. In 1997, she filed a complaint for recovery of possession against the respondents. The Municipal Circuit Trial Court (MCTC) ruled in her favor, ordering the respondents to vacate. The Regional Trial Court (RTC) affirmed this decision. The Court of Appeals, however, reversed the RTC, dismissing Naval’s complaint.

ISSUE

Who has the superior right of possession over the disputed unregistered land, the petitioner who holds a subsequent OCT, or the respondents who derive their claim from a prior registered sale?

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The respondents, as successors-in-interest of Gregorio Galarosa, possess a superior right. The pivotal factor is the prior registration of the 1969 deed of sale to Gregorio under Act No. 3344 . For unregistered land, registration under this law serves as constructive notice to the whole world. Consequently, when Juanita Naval allegedly bought the property in 1972, she was constructively notified of the prior sale to Gregorio. Her subsequent acquisition of an OCT in 1975 did not vest her with a better right because the title was issued over land already validly conveyed to another.
The Court emphasized that the principle of “prior tempore, potior jure” (first in time, stronger in right) applies. Juanita cannot claim good faith as a subsequent buyer because the prior registered transaction operated as notice. Furthermore, the Court noted that Juanita changed her theory on appeal by questioning Ildefonso’s ownership, which is prohibited. The respondents’ long-standing possession, payment of taxes, and construction of improvements further bolster their claim. The petitioner’s OCT, having been issued after the land was already sold, cannot prevail over the rights stemming from the earlier registered transaction.