G.R. No. L-8689; March 30, 1914
LIBRADO MANAS, ET AL., plaintiffs-appellees, vs. MARIA RAFAEL, defendant-appellant.

FACTS:
Both parties claim title to the same parcel of land through purchase from the original registered owner, Regino Bunduk. The trial court found:
1. On August 8, 1893, Regino Bunduk executed a deed of sale in favor of Pedro Manas, the plaintiffs’ predecessor-in-interest. A cautionary note (anotacion preventiva) of this deed was entered in the land register on August 11, 1893.
2. On May 2, 1892, the defendant’s predecessor-in-interest purchased the same land at a judicial sale of Bunduk’s property. The defendant and her predecessor had been in undisturbed possession of the land from 1892 until the filing of the action, a period of 18 to 19 years.

ISSUE:
Which of the two conflicting titles should prevail?

RULING:
The Supreme Court affirmed the trial court’s decision, ruling in favor of the plaintiffs-appellees. The Court applied Article 1473 of the Civil Code, which governs conflicts of sales of the same property to different vendees. For real property, ownership belongs to the person who first recorded the acquisition in the registry. The Court held that the precautionary annotation (anotacion preventiva) made on August 11, 1893, in favor of plaintiffs’ predecessor, constituted a valid registration for this purpose. This was so despite the annotation being precautionary and not a formal definitive entry, as it was made “for lack of necessary indexes.” The Royal Decree of June 15, 1897, gave such precautionary annotations the effect of definitive registries. Consequently, the plaintiffs’ prior registry prevailed over the defendant’s prior possession and judicial sale title.