G.R. No. L-20068, June 26, 1967
Edgardo O. Alzate, plaintiff-appellee, vs. Philippine National Bank, ET AL., defendants. Philippine National Bank, defendant-appellant.

FACTS

The case involves a dispute over a parcel of land. The original owner, Rufino Ellison, sold the land to Emeterio Ramos on March 17, 1944. On February 16, 1946, the Court of First Instance of Manila, upon Ramos’s petition alleging the loss/destruction of Ellison’s title, ordered its reconstitution and the issuance of a new title in Ramos’s name. Consequently, Transfer Certificate of Title (TCT) No. 78189 was issued to Ramos on March 12, 1946. Ramos then sold the land to Pacita T. Javier, leading to the cancellation of TCT No. 78189 and the issuance of TCT No. 2306 in Javier’s name on August 2, 1946. Javier later sold the land to Ismael Alzate (substituted during the case by Edgardo O. Alzate), resulting in the issuance of TCT No. 38647 of Quezon City on October 30, 1957.
Meanwhile, on December 13, 1946, Ramos obtained another certificate of title for the same land, TCT No. 3936 of Manila (later TCT No. 28281 of Quezon City), based on the same March 17, 1944 deed of sale, which was presented for registration and entered in the Register of Deeds’ Day Book on that date in 1944. Subsequently, in a money judgment case against Ramos, the Philippine National Bank (PNB) levied upon the land covered by TCT No. 28281, purchased it at an execution sale, and obtained TCT No. 44422 in its name. The core issue is which certificate of title, Alzate’s TCT No. 38647 or PNB’s TCT No. 44422, is valid.

ISSUE

Which of the two certificates of title (TCT No. 38647 in the name of Ismael/Edgardo Alzate and TCT No. 44422 in the name of the Philippine National Bank) should be considered valid and recognized as evidencing rightful ownership of the land?

RULING

The Supreme Court affirmed the trial court’s decision in favor of plaintiff Edgardo O. Alzate, declaring him the rightful owner. The Court held that where two certificates purport to include the same land, the earlier in date prevails. Alzate’s title, derived from TCT No. 78189 issued to Ramos on March 12, 1946, is earlier than the root of PNB’s title, TCT No. 3936 issued to Ramos on December 13, 1946. Both parties trace their claim to the same deed of sale from Ellison to Ramos, but Javier (Alzate’s predecessor) derived title under the earlier issued certificate. Furthermore, a purchaser at an execution sale acquires only the right, title, and interest of the judgment debtor at the time of the levy. Since Ramos had already sold the land to Javier before the levy, he had no remaining interest that could be acquired by PNB at the execution sale. Therefore, Alzate’s earlier title prevails.