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Realty Sales Enterprise v.

IAC

Two adjacent parcels of land are covered by 3 Torrens titles: TCT No. 20408, TCT No. 303961, and TCT Nos.
333982 and 333985. Carpo sought the nullification of TCT No. 20408 issued in favor of Realty and Macondray
Farms on the ground that the court that issued the decree of registration thereto was not sitting as a land
registration court hence, it does not have jurisdiction to issue the said decree. Carpo further contends that since
the records were destroyed in WW2, reconstitution of the same is necessary before filing a petition for
registration again. Realty contends that it was Carpo’s title which is void for being issued over a parcel of land
registered in the name of another.

Realty and Macondray sought the nullification of TCT Nos. 333982 and 333985 issued in favor of QCDFC on
the ground that the titles involve the same parcels of land in its dispute with Carpo. QCDFC contends that it was
Realty’s title that was void and subsequently sued the Alvendia family for having purchased the land from
QCDFC.

The trial court upheld the validity of Carpo’s title. The CA upheld Realty’s title. Carpo’s title was once again
upheld in his Motion for Reconsideration.

Issues:
Whether or not the trial court has jurisdiction in issuing the decree of registration
Whether or not Carpo was an innocent purchaser for value

Held:
All applications for registration are within the jurisdiction of the CFI of the province where the land is located.
In this case, Realty sought the registration of the subject properties before the CFI sitting as a land registration
court before the records were destroyed. Carpo contends that since the records were not reconstituted, no
pending case is before the CFI hence, without jurisdiction. The SC ruled that a petitioner may seek
reconstitution of the records and continue the case. Jurisdiction is with the CFI and the same remains to be so
until the case is terminated. If they fail to ask for reconstitution, the worst that can happen to them is that they
lose the advantages provided by the reconstitution law. The land registration case remained pending in this case
hence, the CFI continued to have jurisdiction over it.

Carpo was not an innocent purchaser for value. One is considered an innocent purchaser for value only if,
relying on the certificate of title, he bought the property from the registered owner, without notice that some
other person has a right to, or interest in, such property and pays a full and fair price for the same, at the time of
such purchase, or before he has notice of the claim or interest of some other persons in the property. When
Carpo bought the parcel of land, no Torrens system exists yet. However, when he bought them from the
Baltazars (previous owners), an older title in the name of Mayuga (Realty’s predecessor) exists. In the case of
two certificates of title, purporting to include the same land, the earlier in date prevails… In successive
registrations, where more than one certificate is issued in respect of a particular estate or interest in land, the
person claiming under the prior certificate is entitled to the estate or interest; and that person is deemed to hold
under the prior certificate who is the holder of, or whose claims is derived directly or indirectly from the person
who was the holder of the earliest certificate issued in respect thereof.