G.R. No. L-33676. June 30, 1971.
MARIANO PAJOMAYO, ET AL., plaintiffs-appellees, vs. RODRIGO MANIPON and PERFECTA ZULUETA, defendants-appellants.

FACTS

The plaintiffs-appellees, heirs of Diego Pajomayo, filed a complaint for recovery of possession and ownership of a parcel of land. They claimed ownership based on Original Certificate of Title (OCT) No. 1089 issued on November 27, 1931, under a homestead patent in the name of their father. They alleged the defendants-appellants dispossessed them in 1956. The defendants-appellants, in their answer, claimed exclusive ownership by virtue of OCT No. 14034 issued on April 1, 1957, under the Malasique cadastre in the name of Rodrigo Manipon. The parties submitted a stipulation of facts confirming the existence of these two titles covering the same land and agreed to submit the case for decision based thereon.
The trial court ruled in favor of the plaintiffs. It found that OCT No. 1089 was issued earlier than OCT No. 14034. Consequently, it ordered the defendants to vacate the land and directed the Register of Deeds to cancel OCT No. 14034. The defendants appealed, assigning errors that the court ordered cancellation of their title without it being prayed for, that plaintiffs failed to prove their cause of action, and that the court erred in not applying res judicata.

ISSUE

Which of the two conflicting original certificates of title should prevail?

RULING

The Supreme Court affirmed the trial court’s decision, ruling that OCT No. 1089 must prevail. The legal logic is anchored on the principle of indefeasibility of a Torrens title and the rule on prior registration. The Court held that a certificate of title issued pursuant to a homestead patent, once registered, becomes as indefeasible as one issued in judicial registration proceedings after the lapse of one year. The pivotal rule applied is that where two certificates of title are issued to different persons for the same land, the earlier in date prevails. This rule protects the integrity of the Torrens system by favoring the title first entered into the registry. Since OCT No. 1089 (1931) was issued decades before OCT No. 14034 (1957), the earlier title is superior. Necessarily, the later title must be declared void and ordered cancelled to clear the cloud on the title. The Court found no merit in the defense of res judicata, as the prior issuance and registration of the appellees’ title established a superior claim that could not be barred. The trial court’s order for cancellation was a logical consequence of declaring the earlier title valid.