G.R. No. L-42228; May 21, 1935
EL MONTE DE PIEDAD Y CAJA DE AHORROS DE MANILA, plaintiff-appellee, vs. JORGE VELASCO, ET AL., defendants. SIMEON MANUEL, ANGELO MANUEL, JORGE VELASCO, and FRANCISCA PANTIG, appellants.

FACTS

The Roman Catholic Archbishop of Manila acquired ownership of the Dinalupihan Rice Estate in 1894 via a composition title. In 1914, a registration proceeding (G.L.R.O. Record No. 9271) adjudicated the hacienda to the Archbishop, overruling an opposition by the Government. A Torrens certificate of title was issued in 1922 pursuant to that 1914 decree. The Archbishop later conveyed the property to El Monte de Piedad y Caja de Ahorros, which holds Transfer Certificate of Title No. 1301. Meanwhile, the defendants obtained homestead patents from the Bureau of Lands for portions of the same estate in 1917, 1918, and 1919. El Monte de Piedad sought to recover these parcels, and the trial court ruled in its favor, declaring the homestead titles null and ordering their cancellation.

ISSUE

Which title prevails: the Torrens title originating from a 1914 registration decree or the homestead patents issued by the administrative branch after that decree?

RULING

The Torrens title of the plaintiff prevails. The 1914 decree in the registration proceeding, which became the basis for the 1922 Torrens title, was conclusive and binding upon all parties, including the government, before the homestead patents were issued. Homestead patents are granted through administrative proceedings, which are inferior to a judicial decree of registration. Since the government had notice of the 1914 registration decree when it later issued the homestead patents, the Torrens title is superior. The defendants’ claim for improvements is denied as they were not possessors in good faith after the 1914 decree. The judgment of the trial court is affirmed.

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