[Case No. 96]: Liao vs.

CA
Double Sale
G.R. Nos. 102961-62, January 27, 2000
Pardo, J.

FACTS: On March 5, 1986, Estrella Mapa filed with the Regional Trial Court, Quezon
City, Branch 99 a petition for reconstitution of documents and issuance of certificates of
title over certain parcels of land. He claims that the Director of lands issued certificates
of sales to Vicente Salgado over the said parcels of land in accordance with the known
Friar Lands Act. And that, On April 12, 1930, Salgado assigned the property to him
(Mapa). On June 30, 1986, The RTC ruled that such Assignment of Sales Certificates
were valid and registrable titles. The RTC then issued an order to transfer the Certificate
of Title in the name of Estrella Mapa. However, such titles were in conflict with several
existing certificates of titles. This led I.C. Cruz Construction, Inc. (ICC) and Arle Realty
Development to file, with the CA, separate petitions for the annulment of the Order on
June 30, 1986. In a preliminary conference, Jesus Liao appeared with his counsel and
claimed that he purchased the parcels of land from Palmera by virtue of a Deed of
Omnibus Assignment dated August 23, 1990. The CA declared the RTC decision null
and void.

ISSUE: WON the Court of Appeals erred in upholding the annulment of the order of the
trial court in LRC Case No. 3369 (86) authorizing issuance of titles on the basis of sales
certificates and technical descriptions as reconstituted by the Land Registration
Commission?

RULING: NO. The CA was correct in its decision of annulment of the RTC ruling.
When two certificates of title are issued to different persons covering the same land in
whole or in part, the earlier in date must prevail, and, in case of successive registrations
where more than one certificate is issued over the same land, the person holding a prior
certificate is entitled to the land as against a person who relies on a subsequent
certificate." A certificate is not conclusive evidence of title if the same land had been
registered and an earlier certificate for the same is in existence. In such case, private
respondent’s title must be respected. They have in their favor the law that protects
holders of title under the Torrens System of land registration. Although title does not
vest ownership, time and again, the SC has ruled that a torrens certificate is evidence of
an indefeasible title to property in favor of the person whose name appears thereon.
Thus, the Court of Appeals correctly annulled the trial court's order allowing registration
of the subject property in the name of Estrella Mapa and her successors in interest.