GR L 3456; (August, 1907) (Digest)
G.R. No. L‑3456
EN BANC 14 August 1907
—
FACTS
1. Application for registration Joseph N. Wolfson filed on 16 Nov 1905 with the Court of Land Registration a petition to register his claimed ownership of a 658 m² parcel at 106‑112 Calle Solana, Walled City. He asserted he bought the land from D.A.J. Gies, occupied it, and that it was free of encumbrances.
2. Adverse report The examiner of titles reported that the title could not be registered. Wolfson nonetheless reiterated his request on 22 Dec 1905.
3. Competing claims Findlay & Co. (via Lorenzo D. Holden) consented to registration but only subject to a mortgage in its favor.
Elias C. Reyes (12 Jan 1906) claimed the land belonged to the late Lorenzo Fernández, named him as custodian, and obtained letters of administration of Fernández’s intestate estate, making him the judicial administrator of the sole real‑estate asset.
City of Manila (via Edmond Block, 12 Feb 1906) asserted that Fernández died intestate without heirs, so the city was entitled to the lot.
Obras PĂas de la Sagrada Mitra del Arzobispado de Manila (16 Feb 1906) alleged an existing lien dating from 1821 in its favor, still valid because never redeemed.
4. Judgment The Land Registration Court denied Wolfson’s application (10 Apr 1906). Wolfson appealed, filing a bill of exceptions and a petition for a new trial, contending the decision was contrary to law and evidence.
—
ISSUE
Whether Joseph N. Wolfson, as purchaser from Anthony J. Gies, possessed a valid title that could be registered, given that the purported transfer chain began with Elias C. Reyeswho allegedly had no lawful ownership or prescription title over the property.
—
RULING
The Supreme Court affirmed the lower court’s denial of registration, holding:
1. Title transfers are limited to the grantor’s own rights. Under Art. 1511 Civil Code, a vendee acquires only the rights of the vendor; no transfer can convey a title that the vendor does not possess.
2. Reyes lacked a legitimate title. He was merely an administrator of an intestate estate with no proven ownership; consequently, his possessionthough possibly continuous for twelve yearswas not “true and valid” for prescription (Art. 1953 Civil Code).
3. Consequent transfers are void. Because Reyes could not convey ownership to Anthony J. Gies, Gies had no title to convey to Wolfson. Wolfson therefore was not the owner nor holder of a registrable title.
4. The judgment was legally sound. The Court correctly applied the doctrines of title transfer and prescription, and thus affirmed the decision with costs against the appellant.
Decision: Judgment denying registration is AFFIRMED; costs imposed on appellant Wolfson.
