61 Phil. 467 – Civil Law – Law on Property – Primacy of a Torrens Title – Compensation
In 1894, the Roman Catholic Church of Manila acquired ownership over the Dinalupihan Rice Estate. In 1914, a decree of registration was handed over by the court in favor of the Roman Catholic Church (RCC) of Manila. In 1922, a Torrens title was issued in favor of the RCC of Manila pursuant to the 1914 decision. The RCC of Manila later conveyed ownership of the said rice estate to Monte de Piedad.
Meanwhile, the Bureau of Lands issued homestead patents to Mateo Peñaflor in 1917, to Anacleto Manuel in 1918 and Jorge Velasco in 1919. The patents pertain to various portions of the said rice estate.
Monte de Piedad then sought to recover those lands. Velasco et al invoked Section 102 of Act No. 2874 which allegedly entitles them for claims on improvements over the land.
ISSUE: Whether or not Monte de Piedad’s Torrens title is superior over the homestead patents considering that the title was issued in 1922.
HELD: Yes. Monte de Piedad’s title is superior to the homestead patents issued to Velasco et al. It is true that the Torrens title was not issued until 1922, but the decision in pursuance of which the sale was issued was rendered in 1914. And when the homestead patents were handed down, the government had notice of said decision.
Note that the Torrens title is conclusive and binding upon all the world. On the other hand, the homestead patent proceeding under the Public Land Act is just administrative.
Velasco et al are not entitled to improvements over the land. Act 2874 was promulgated long after the Torrens and homesteads were issued. The time they were in possession of the said portions of land have already compensated them.
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