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LAND TITLES & DEEDS

1. TORRENS SYSTEM
Torrens System
It is a system for registration of land under which, upon the
landowners application, the court may, after appropriate
proceedings, direct the register of deeds for the issuance of a
certificate of title.
It is judicial in nature.
*Registration is NOT a mode in acquiring ownership; it only
confirms ownership which can be directly attacked.
*Registration is not equivalent to legal title.
*When someone opposes the registration, he/she must show an
INTEREST on the property that is being disputed.
*When there is final judgment, bring the Court decision to the Land
Registration Office to have it registered.
*Under the Torrens System, registration only gives validity to the
transfer or creates a lien upon the land. It merely confirms, but does
not confer ownership.
Effects of Issuance of Title
1) The land is placed under the operation of the Torrens System
2) Land is relieved from all claims except those noted thereon and
provided by law
3) Title to the land becomes non-prescriptable
4) The land becomes incontrovertible and indefeasible
5) The certificate of title is not subject to collateral attack

*The Torrens Title is conclusive against the whole world, it is

guaranteed to be indefeasible, unassailable, and imprescriptible.
2 Types of Torrens Certificate of Title
1. Original Certificate of Title (OCT)
The first title issued in the name of the registered owner
by the Register of Deeds covering a parcel of land,
which had been registered under the Torrens System by
virtue of a judicial or administrative proceeding.
It consists of 1 original copy filed in the Register of
Deeds, and the owners duplicate certificate delivered
to the owner.
2. Transfer Certificate of Title (TCT)
The title issued by the Register of Deeds in favour of a
transferee to whom the ownership of a registered land
has been transferred by any legal mode of conveyance
(ex. Sale, Donation).
It also consists of an original and an owners duplicate
certificate.
Consuelo Legarda vs. N.M. Saleeby (G.R. No. L-8936 2 October
1915)
The real purpose of that system is to quiet title to land; to put a stop
forever to any question of the legality of the title, except claims which
were noted at the time of registration, in the certificate, or which may
arise subsequent thereto. That being the purpose of the law, it would
seem that once a title is registered the owner may rest secure, without
the necessity of waiting in the portals of the court, or sitting in the
mirador de su casa, to avoid the possibility of losing his land. Of
course, it can not be denied that the proceeding for the registration of
land under the Torrens System is judicial. It is clothed with all the

forms of an action and the result is final and binding upon all the
world. It is an action in rem.
While the proceeding is judicial, it involves more in its consequences
than does an ordinary action. All the world are parties, including the
government. After the registration is complete and final and there
exists no fraud, there are no innocent third parties who may claim an
interest. The rights of all the world are foreclosed by the decree of
registration. The government itself assumes the burden of giving
notice to all parties. To permit persons who are parties in the
registration proceeding (and they are all the world) to again litigate the
same questions, and to again cast doubt upon the validity of the
registered title, would destroy the very purpose and intent of the law.
The registration, under the Torrens system, does not give the owner
any better title than he had. If he does not already have a perfect title,
he can not have it registered. Fee simple titles only may be registered.
The certificate of registration accumulates in open document a precise
and correct statement of the exact status of the fee held by its owner.
The certificate, in the absence of fraud, is the evidence of title and
shows exactly the real interest of its owner. The title once registered,
with very few exceptions, should not thereafter be impugned, altered,
changed, modified, enlarged, or diminished, except in some direct
proceeding permitted by law. Otherwise all security in registered titles
would be lost. A registered title can not be altered, modified, enlarged,
or diminished in a collateral proceeding and not even by a direct
proceeding, after the lapse of the period prescribed by law.
Purpose of Land Registration
To quiet title to land and stop forever any question as to the
legality of said title.

To serve as constructive notice to all persons form the time of

such registering, filling or entering of every conveyance,
mortgage, lease, lien, attachment, order, judgment, instrument
or entry affecting registered land.
To notify and protect the interests of strangers to a given
transaction, who may be ignorant thereof.
To enable every registered owner and every subsequent
purchaser of registered and taking a certificate of title for value
and in good faith to hold the same free from all
encumbrances.
To prevent fraudulent transactions. No voluntary instrument
shall be registered by the Registrar of Deeds, unless the
owners duplicate certificate is presented with such instrument.
To enable the Register of Deeds to maintain a repository of
all instruments affecting registered land.
To issue a certificate of title to the owner, which shall be the
best evidence of his ownership of the land described therein.
To guarantee the integrity of land titles and to protect their
indefeasibility once the claim of ownership is established and
recognised.
Nature of Land Registration
Judicial proceedings for the registration of lands throughout the
Philippines shall be in Rem and shall be based on the generally
accepted principles underlying the Torrens System.
Difference Between Title & Deed
Title
The right of the owner or the extent of his interest and by
means of which he can maintain control, and as a rule, assert
his right to the exclusive possession and enjoyment of the
property.

Deed
A written instrument executed in accordance with law, wherein
a person grants or conveys to another certain land, right, or
interests.
2. REGALIAN DOCTRINE
Modes of Acquiring Title
1. By Public Grant
By administrative process, the government transfers
land to a private individual by issuance of sales patent
or special patents.
2. By Acquisitive Prescription
Must be in the concept of an owner.
Ordinary Prescription possession in good faith and
with just title; 10 years.
Extraordinary Prescription adverse possession
without need of title or good faith; 30 years.
3. By Accretion
Art. 457, NCC
4. By Reclamation
It is the method of filling submerged land by deliberate
acts and reclaiming title thereto.
5. By Voluntary Transfer
The transfer is given by the voluntary execution of a
deed of conveyance in certain prescribed form,
completed by the recording or registration thereof.

6. By Involuntary Alienation
This does not require the consent or cooperation of the
owner of the land and is usually carried out against his
will.
Usual forms of involuntary alienation are expropriation
or condemnation proceedings.
Other examples are escheat, reversion, seizure based on
tax delinquency, levy on attachment and levy on
execution.
7. By Descent or Devise
By Descent acquired by virtue of hereditary
succession to the estate of a deceased owner.
By Devise succession need not be in favour of a
relative.
Present Rule in Determining What is Alienable
Jean Tan, et al. vs. Republic of the Philippines (G.R. No. 193443
16 April 2012)
Presidential Decree No. 1529 (P.D. No. 1529), otherwise known as the
Property Registration Decree, is a codification of all the laws
relative to the registration of property and Section 14 thereof specifies
those who are qualified to register their incomplete title over an
alienable and disposable public land under the Torrens System.
Particularly:
Section 14. Who may apply. The following persons may file in
the proper Court of First Instance an application for
registration of title to land, whether personally or through their
authorized representatives:

(1) Those who by themselves or through their

predecessors-in-interest have been in open, continuous,
exclusive and notorious possession and occupation of
alienable and disposable lands of the public domain
under a bona fide claim of ownership since June 12,
1945, or earlier.
(2) Those who have acquired ownership of private
lands by prescription under the provision of existing
laws.
(3) Those who have acquired ownership of private
lands or abandoned river beds by right of accession or
accretion under the existing laws.
(4) Those who have acquired ownership of land in any
other manner provided for by law.
As this Court clarified in Heirs of Malabanan v. Republic of the
Philippines, and Republic of the Philippines v. East Silverlane Realty
Development Corporation, Section 14(1) covers alienable and
disposable lands while Section 14(2) covers private property.
Thus, for ones possession and occupation of an alienable and
disposable public land to give rise to an imperfect title, the same
should have commenced on June 12, 1945 or earlier. On the other, for
one to claim that his possession and occupation of private property has
ripened to imperfect title, the same should have been for the
prescriptive period provided under the Civil Code. Without need for
an extensive extrapolation, the private property contemplated in
Section 14(2) is patrimonial property as defined in Article 421 in
relation to Articles 420 and 422 of the Civil Code.

Going further, it was explained in Heirs of Malabanan and East

Silverlane, that possession and occupation of an alienable and
disposable public land for the periods provided under the Civil Code
will not convert it to patrimonial or private property. There must be an
express declaration that the property is no longer intended for public
service or the development of national wealth. In the absence thereof,
the property remains to be alienable and disposable and may not be
acquired by prescription under Section 14(2) of P.D. No. 1529. Thus:
In Heirs of Malabanan, this Court ruled that possession and
occupation of an alienable and disposable public land for the
periods provided under the Civil Code do not automatically
convert said property into private property or release it from
the public domain. There must be an express declaration that
the property is no longer intended for public service or
development of national wealth.
Without such express
declaration, the property, even if classified as alienable or
disposable, remains property of the State, and thus, may not be
acquired by prescription.
Nonetheless, Article 422 of the Civil Code states that
[p]roperty of public dominion, when no longer intended for
public use or for public service, shall form part of the
patrimonial property of the State. It is this provision that
controls how public dominion property may be converted into
patrimonial property susceptible to acquisition by prescription.
After all, Article 420 (2) makes clear that those property
which belong to the State, without being for public use, and
are intended for some public service or for the development of
the national wealth are public dominion property. For as
long as the property belongs to the State, although already
classified as alienable or disposable, it remains property of the

public dominion if when it is "intended for some public service

or for the development of the national wealth". (emphasis
supplied)
Accordingly, there must be an express declaration by the State that the
public dominion property is no longer intended for public service or
the development of the national wealth or that the property has been
converted into patrimonial. Without such express declaration, the
property, even if classified as alienable or disposable, remains property
of the public dominion, pursuant to Article 420(2), and thus incapable
of acquisition by prescription. It is only when such alienable and
disposable lands are expressly declared by the State to be no longer
intended for public service or for the development of the national
wealth that the period of acquisitive prescription can begin to run.
Such declaration shall be in the form of a law duly enacted by
Congress or a Presidential Proclamation in cases where the President is
duly authorized by law.
In other words, for one to invoke the provisions of Section 14(2) and
set up acquisitive prescription against the State, it is primordial that the
status of the property as patrimonial be first established. Furthermore,
the period of possession preceding the classification of the property as
patrimonial cannot be considered in determining the completion of the
prescriptive period.
Regalian Doctrine
Republic of the Philippines vs. Marlon Medida (G.R. No. 195097
13 August 2012)
Under the Regalian Doctrine, all lands of the public domain belong to
the State, and the State is the source of any asserted right to ownership
in land and charged with the conversion of such patrimony. The same
doctrine also states that all lands not otherwise appearing within

private ownership are presumed to belong to the State. Hence, anyone

who applies for registration of ownership over a parcel of land has the
burden of overcoming the presumption that the land sought to be
registered forms part of the public domain.
This Court also holds that the alienability and disposability of land are
not among the matters that can be established by mere admissions, or
even the agreement of parties. The law and jurisprudence provide
stringent requirements to prove such fact. Our Constitution, no less,
embodies the Regalian doctrine that all lands of the public domain
belong to the State, which is the source of any asserted right to
ownership of land. The courts are then empowered, as we are dutybound, to ensure that such ownership of the State is duly protected by
the proper observance by parties of the rules and requirements on land
registration.
Republic of the Philippines vs. Heirs of Maxima Lachica (G.R. No.
157485 26 March 2014)
All lands of the public domain belong to the State and that lands not
appearing to be clearly within private ownership are presumed to
belong to the State.
As this Court held in the fairly recent case of Valiao v. Republic (G.R.
No. 170757, November 28, 2011,):
Under the Regalian doctrine, which is embodied in our
Constitution, all lands of the public domain belong to the State,
which is the source of any asserted right to any ownership of
land. All lands not appearing to be clearly within private
ownership are presumed to belong to the State. Accordingly,
public lands not shown to have been reclassified or released as
alienable agricultural land or alienated to a private person by

the State remain part of the inalienable public domain. Unless

public land is shown to have been reclassified as alienable or
disposable to a private person by the State, it remains part of
the inalienable public domain. Property of the public domain
is beyond the commerce of man and not susceptible of private
appropriation and acquisitive prescription.
Occupation
thereof in the concept of owner no matter how long cannot
ripen into ownership and be registered as a title. The burden
of proof in overcoming the presumption of State ownership of
the lands of the public domain is on the person applying for
registration (or claiming ownership), who must prove that the
land subject of the application is alienable or disposable. To
overcome this presumption, incontrovertible evidence must be
established that the land subject of the application (or claim) is
alienable or disposable.
Accordingly, in the case at bar, the failure of petitioner Republic to
show competent evidence that the subject land was declared a
timberland before its formal classification as such in 1960 does
not lead to the presumption that said land was alienable and
disposable prior to said date. On the contrary, the presumption is that
unclassified lands are inalienable public lands.
It is therefore the respondents which have the burden to identify a
positive act of the government, such as an official proclamation,
declassifying inalienable public land into disposable land for
agricultural or other purposes. Since respondents failed to do so, the
alleged possession by them and by their predecessors-in-interest is
inconsequential and could never ripen into ownership.
3. CITIZENSHIP REQUIREMENT
Sec. 7, Art. XII, Const.

Save in cases of hereditary succession, no private lands shall be

transferred or conveyed except to individuals, corporations, or
associations qualified to acquire or hold lands of the public domain.
Sec. 8, Art. XII, Const.
Notwithstanding the provisions of Section 7 of this Article, a naturalborn citizen of the Philippines who has lost his Philippine citizenship
may be a transferee of private lands, subject to limitations provided by
law. (EXCEPTION)
Alexander Krivenko vs. Register of Deeds (G.R. No. L-630 15
November 1947)
Facts:
Krivenko bought a residential lot and its registration was denied by the
Register of Deeds on the ground that being an alien, he cannot acquire
land in this jurisdiction. When Krivenko brought the case to the CFI,
the court rendered judgement sustaining the refusal of the Register of
Deeds.
Issue:
Whether Krivenko, an alien, may own private lands in the Philippines.
Held:
The SC had ruled that Krivenko can not own private lands in the
Philippines.
Under section 1 of Article XIII of the Constitution, natural resources,
with the exception of public agricultural land, shall not be alienated,
and with respect to public agricultural lands, their alienation is limited
to Filipino citizens. But this constitutional purpose conserving
agricultural resources in the hands of Filipino citizens may easily be
defeated by the Filipino citizens themselves who may alienate their

agricultural lands in favour of aliens. It is partly to prevent this result

that section 5 is included in Article XIII, and it reads as follows:
Sec. 5. Save in cases of hereditary succession, no private
agricultural land will be transferred or assigned except to
individuals, corporations, or associations qualified to acquire
or hold lands of the public domain in the Philippines.
This constitutional provision closes the only remaining avenue through
which agricultural resources may leak into aliens' hands. It would
certainly be futile to prohibit the alienation of public agricultural lands
to aliens if, after all, they may be freely so alienated upon their
becoming private agricultural lands in the hands of Filipino citizens.
Undoubtedly, as above indicated, section 5 is intended to insure the
policy of nationalization contained in section 1. Both sections must,
therefore, be read together for they have the same purpose and the
same subject matter. It must be noticed that the persons against whom
the prohibition is directed in section 5 are the very same persons who
under section 1 are disqualified to acquire or hold lands of the public
domain in the Philippines. And the subject matter of both sections is
the same, namely, the non-transferability of agricultural land to
aliens.
Since agricultural land under section 1 includes residential lots, the
same technical meaning should be attached to agricultural land
under section 5. It is a rule of statutory construction that a word or
phrase repeated in a statute will bear the same meaning throughout the
statute, unless a different intention appears.
Republic of the Philippines vs. CA & Spouses De Vega (G.R. No.
108998 - 24 August 1994)
Facts:

1. On 17 June 1978, respondent spouses bought Lots 347 and 348,

Cad. s38-D, as their residence with a total area of 91.77 sq. m. situated
in San Pablo City, from one Cristeta Dazo Belen (Rollo, p. 41).
At the time of the purchase, respondent spouses where then
natural-born Filipino citizens.
2. On 5 February 1987, the spouses filed an application for registration
of title of the two (2) parcels of land before the Regional Trial Court of
San Pablo City, Branch XXXI.
This time, however, they were no longer Filipino citizens and
have opted to embrace Canadian citizenship through
naturalization.
3. An opposition was filed by the Republic and after the parties have
presented their respective evidence, the court a rendered a decision
confirming private respondents' title to the lots in question.
4. On appeal, the CA affirmed the decision of the trial court based on
the following ratiocination:
In the present case, it is undisputed that both applicants were
still Filipino citizens when they bought the land in controversy
from its former owner. For this reason, the prohibition against
the acquisition of private lands by aliens could not apply. In
justice and equity, they are the rightful owners of the subject
realty considering also that they had paid for it quite a large
sum of money.
Issue:
Whether or not a foreign national can apply for registration of title
over a parcel of land which he acquired by purchase while still a

citizen of the Philippines, from a vendor who has complied with the
requirements for registration under the Public Land Act (CA 141).
Held:
The Court disagreed on the petition to seek to defeat respondents'
application for registration of title on the ground of foreign nationality.
The SC had stated that:
As could be gleaned from the evidence adduced, the private
respondents do not rely on fee simple ownership based on a Spanish
grant or possessory information title under Section 19 of the Land
Registration Act; the private respondents did not present any proof that
they or their predecessors-in-interest derived title from an old Spanish
grant such as (a) the titulo real or royal grant (b) the concession
especial or especial grant; (c) the composicion con el estado title or
adjustment title; (d) the titulo de compra or title by purchase; and (e)
the informacion posesoria or possessory information title, which
could become a titulo gratuito or a gratuitous title (Director of
Forestry v. Muoz, 23 SCRA 1183 [1968]). The primary basis of their
claim is possession, by themselves and their predecessors-in-interest,
since time immemorial.
Pursuant thereto, Batas Pambansa Blg. 185 was passed into law, the
relevant provision of which provides:
Sec.2. Any natural-born citizen of the Philippines who has lost
his Philippine citizenship and who has the legal capacity to
enter into a contract under Philippine laws may be a transferee
of a private land up to a maximum area of one thousand square
meters, in the case of urban land, or one hectare in the case of
rural land, to be used by him as his residence. In the case of

married couples, one of them may avail of the privilege herein

granted; Provided, That if both shall avail of the same, the
total area acquired shall not exceed the maximum herein fixed.
In case the transferee already owns urban or rural lands for residential
purposes, he shall still be entitled to be a transferee of an additional
urban or rural lands for residential purposes which, when added to
those already owned by him, shall not exceed the maximum areas
herein authorized.
From the adoption of the 1987 Constitution up to the present, no other
law has been passed by the legislature on the same subject. Thus,
what governs the disposition of private lands in favour of a naturalborn Filipino citizen who has lost his Philippine citizenship remains to
be BP 185.
Even if private respondents were already Canadian citizens at the time
they applied for registration of the properties in question, said
properties as discussed above were already private lands;
consequently, there could be no legal impediment for the registration
thereof by respondents in view of what the Constitution ordains. The
parcels of land sought to be registered no longer form part of the
public domain. They are already private in character since private
respondents' predecessors-in-interest have been in open, continuous
and exclusive possession and occupation thereof under claim of
ownership prior to June 12, 1945 or since 1937. The law provides that
a natural-born citizen of the Philippines who has lost his Philippine
citizenship may be a transferee of a private land up to a maximum area
of 1,000 sq.m., if urban, or one (1) hectare in case of rural land, to be
used by him as his residence (BP 185).

It is undisputed that private respondents, as vendees of a private land,

were natural-born citizens of the Philippines. For the purpose of
transfer and/or acquisition of a parcel of residential land, it is not
significant whether private respondents are no longer Filipino citizens
at the time they purchased or registered the parcels of land in question.
What is important is that private respondents were formerly naturalborn citizens of the Philippines, and as transferees of a private land,
they could apply for registration in accordance with the mandate of
Section 8, Article XII of the Constitution. Considering that private
respondents were able to prove the requisite period and character of
possession of their predecessors-in-interest over the subject lots, their
application for registration of title must perforce be approved.
The dissenting opinion, however, states that the requirements in BP
185, must also be complied with by private respondents. Specifically,
it refers to Section 6, which provides:
Sec.6. In addition to the requirements provided for in other
laws for the registration of titles to lands, no private land shall
be transferred under this Act, unless the transferee shall submit
to the register of deeds of the province or city where the
property is located a sworn statement showing the date and
place of his birth; the names and addresses of his parents, of
his spouse and children, if any; the area, the location and the
mode of acquisition of his landholdings in the Philippines, if
any; his intention to reside permanently in the Philippines; the
date he lost his Philippine citizenship and the country of which
he is presently a citizen; and such other information as may be
required under Section 8 of this Act.
The Court is of the view that the requirements in Sec. 6 of BP 185 do
not apply in the instant case since said requirements are primarily

directed to the register of deeds before whom compliance therewith is

to be submitted. Nowhere in the provision is it stated, much less
implied, that the requirements must likewise be submitted before the
land registration court prior to the approval of an application for
registration of title.
An application for registration of title before a land registration court
should not be confused with the issuance of a certificate of title by the
register of deeds. It is only when the judgment of the land registration
court approving the application for registration has become final that a
decree of registration is issued. And that is the time when the
requirements of Sec. 6, BP 185, before the register of deeds should be
complied with by the applicants. This decree of registration is the one
that is submitted to the office of the register of deeds for issuance of
the certificate of title in favour of the applicant. Prior to the issuance
of the decree of registration, the register of deeds has no participation
in the approval of the application for registration of title as the decree
of registration is yet to be issued.
4. ORIGINAL REGISTRATION
Nature Proceeding brought before the RTC (as a land registration
court) to determine title or ownership of land on the basis of an
application for registration or answer/opposition by a claimant in a
cadastral registration.
Modes of Giving the Public Notice of Initial Hearing
a. Publication
Publication of Notice and Filing of Application and
date and place of hearing once in the Official Gazette
and once in a newspaper of general circulation in the
Philippines.

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b. Posting
Copy of the notice of initial hearing to be posted by the
sheriff of the province or city, as the case may be, or by
his deputy in a conspicuous place on each parcel of land
included in the application and also in a conspicuous
place on the bulletin board of the municipal building of
the municipality or city in which the land or portion
thereof is situated, 14 days at least from the date of the
initial hearing.
c. Mailing
Made using registered mail addressed to the persons
indicated.
*If the publication is made after the date of the initial hearing, the
entire proceeding will be NULL and VOID because publication must
precede the hearing. This is because the Court was not able to
acquire jurisdiction over the property.
*This 3 Notice Requirement is MANDATORY because it is to confer
the RTC jurisdiction.
5. SUBSEQUENT REGISTRATION
Where incidental matters after original registration may be
brought before the land registration court by way of motion or
petition filed by the registered owner or a party in interest.
Rules as to the necessity and effects of registration in general:
1. Except a will that purports to convey or affect of the deeds
of sale, mortgage, or lease or other voluntary 2 purposes:
a. as a contract between the parties thereto, and

b. as evidence of authority to the Register of Deeds to

register such documents
2. It is only the act of registering the instrument in the Register
of Deeds of the province or city where the land lies which is
the operative act that conveys ownership or affects the land
insofar as third persons are concerned.
3. The act of registration creates a constructive notice to the
whole world of such voluntary or involuntary instrument or
court writ or process
*This could either be judicial or administrative.
*If there is a defect with regards to the Publication of the Notices,
then the proceeding will be VOID.
6. NON-REGISTRABLE PROPERTIES
Art. 420, NCC
Those intended for public use, such as roads, rivers, torrents,
ports and bridges constructed by the State, banks shores,
roadsteads, and others of similar character.
Those which belong to the State, without being for public use,
and are intended for some public service or for the
development of the national wealth.
Arts. 5 & 6, Water Code (PD 1067)
Rivers and their natural beds
Continuous or intermittent waters of springs and brooks
running in their natural beds and the beds themselves
Natural lakes and lagoons

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All other categories of surface waters such as water flowing

over lands, water from rainfall whether natural or artificial, and
water from agriculture runoff, seepage and drainage
Atmospheric water
Subterranean or ground water
Seawater

Better Right
Refers to a right which must have been acquired by a third
party independently of the unregistered deed, such, for
instance, as title by prescription, and that it has no reference to
rights acquired under that unregistered deed itself.

Found in Private Lands

Continuous or intermittent waters rising on such lands
Lakes and lagoons naturally rising on such lands
Rain water falling on such lands
Subterranean or ground water
Waters in swamps and marshes

Effects of Transactions Covering Unregistered Land

1. Between the Parties even if the transaction is not registered,
the contract is VALID and BINDING.
2. As Among Third Persons the law requires that in order for
the transaction to be binding to third persons, the same must be
registered.

Regalian Doctrine under the Constitution

Forrest or timberland, public forest, forest reserve lands,
mineral lands
7. DEALINGS WITH UNREGISTERED LAND
Recording of instruments relating to unregistered lands
No deed, conveyance, mortgage, lease, or other voluntary
instrument affecting land not registered under the Torrens
System shall be valid, except as between the parties thereto,
unless such instrument shall be been recorded in the manner
herein prescribed in the Register of Deeds for the province or
city where the land lies (Sec. 113, PD 1529).
Registration under Sec. 113 cannot defeat a person with a better
right
Registration under Sec. 113 (Act No. 3344) is not preceded by
any investigation, judicial or administrative, as to the validity
or the efficacy of the title sought to be recorded.

Registration creates constructive notice only to future dealers in

unregistered land
Registration under Act No. 3344 does not afford full
protection, and the title registered in accordance therewith must
yield to a prior and valid title though unregistered, for
registration under the said Act can only affect rights or interests
subsequent to the registration; it is notice only to future dealers
of the land.