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Mirror Doctrine

A person dealing with registered land has a right to rely on the Torrens certificate of title and to
dispense with the need of inquiring further except when the party has actual knowledge of facts and
circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser
has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably
prudent man to inquire into the status of the title of the property in litigation. The presence of anything
which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and
investigate the title of the vendor appearing on the face of said certificate. One who falls within the
exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith
and, hence, does not merit the protection of the law. (Sandoval v. Court of Appeals, G.R. No. 106657,
August 1, 1996)

Legarda vs. Saleeby (Rule in double registration)

We have decided, in case of double registration under the Land Registration Act, that the owner of the
earliest certificate is the owner of the land.

Laws on Land Registration


1. Public Land Act (Commonwealth Act No. 141) currently in use
2. Land Registration Act (Act No. 496)
3. Cadastral Act (Act No. 2259)
4. Property Registration Decree ( PD No. 1529) supersedes all laws relative to registration of
property

Jurisdiction in land proceedings, which court has jurisdiction over plenary proceedings? RTC
Can be delegated to first level courts? NO, except for
Delegated jurisdiction in cadastral and land registration cases. – Metropolitan Trial Courts, Municipal
Trial Courts, and Municipal Circuit Trial Courts may be assigned by the Supreme Court to hear and
determine cadastral or land registration cases covering lots where there is no controversy or opposition,
or contested lots the where the value of which does not exceed One hundred thousand pesos
(P100,000.00), such value to be ascertained by the affidavit of the claimant or by agreement of the
respective claimants if there are more than one, or from the corresponding tax declaration of the real
property. Their decisions in these cases shall be appealable in the same manner as decisions of the
Regional Trial Courts. (as amended by R.A. No. 7691)

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