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METROPOLITAN WATERWORKS v. CA

This case has been cited 9 times or more.

2015-08-03
DEL CASTILLO, J.
From the foregoing, it is apparent that at the time the predecessor-in-interest of defendants-appellants were issued its titles in 1979, Lots 91, 92, and 96 now owned by the Davis spouses were already in existence. As testified to by surveyor Petronilo Ayson, it was Lots 91, 92 and 96 that were overlapped by Lots 3, 4 and 5 and not the [other way around] since the defendants-appellants' lots resulted only after the subdivision survey of Lot 72 in 1982. In MWSS vs. Court of Appeals,[15] the Honorable Supreme Court pronounced:"Where two certificates (of title) purport to include the same land, the earlier in date prevails. In successive registrations, where more than one certificate is issued in respect of a particular estate or interest in land, the person claiming under the prior certificate is entitled to the estate or interest; and the person is deemed to hold under the prior certificate who is the holder of, or whose claim is derived directly or indirectly from the person who was the holder of the earliest certificate issued in respect thereof."
2015-01-14
LEONARDO-DE CASTRO, J.
Respondents filed their Comment [to the Republic's intervention][59] on June 1, 2005.  Interestingly, respondents now contend that their TCT Nos. 265778  and  285313  are  derivatives  of  OCT No. 994 registered on April 19, 1917, hence,  they capitalize on the rulings of this Court in Metropolitan Waterworks and Sewerage Systems (MWSS) v. Court of Appeals[60] and Heirs of Luis J. Gonzaga v. Court of Appeals[61] that those titles derived from OCT No. 994 registered on April 19, 1917 prevail over those titles derived from OCT No. 994 registered on May 3, 1917 considering the priority of the date of registration.
2012-02-01
DEL CASTILLO, J.
Petitioners are oversimplifying the rule.  The principle that the earlier title prevails over a subsequent one applies when there are two apparently valid titles over a single property. The existence of the earlier valid title renders the subsequent title void because a single property cannot be registered twice.  As stated in Metropolitan Waterworks and Sewerage Systems v. Court of Appeals,[81] which petitioners themselves cite, "a certificate is not conclusive evidence of title if it is shown that the same land had already been registered and an earlier certificate for the same is in existence."  Clearly, a mere allegation of an earlier title will not suffice.
2011-06-08
VILLARAMA, JR., J.
Subsequently, on January 31, 2005, the Court of Appeals promulgated its assailed Decision in CA-G.R. SP No. 62211, setting aside the RTC judgment and dismissing Phil-Ville's complaint.  The appellate court held that the RTC had no jurisdiction to hear Phil-Ville's complaint as it effectively seeks to annul the Order dated May 25, 1962 of the CFI in LRC No. 4557, which directed the substitution of the late Eleuteria Rivera and her co-heirs in place of Maria de la Concepcion Vidal as registered owners on OCT No. 994. The appellate court likewise affirmed the validity of OCT No. 994 registered on April 19, 1917 citing the Supreme Court Decisions in Metropolitan Waterworks and Sewerage Systems v. Court of Appeals[32] and Heirs of Luis J. Gonzaga v. Court of Appeals[33] as precedents.
2010-03-09
VELASCO JR., J.
Some of said alleged heirs were able to procure Transfer Certificates of Title (TCTs) over portions of the Maysilo Estate. They also had led this Court to believe that OCT No. 994 was registered twice, thus, in Metropolitan Waterworks and Sewerage Systems (MWSS) v. Court of Appeals,[4] reiterated in Heirs of Luis J. Gonzaga v. Court Of Appeals,[5] the Court held that OCT No. 994 dated April 19, 1917, and not May 3, 1917, was the valid title by virtue of the prior registration rule.
2009-11-25
NACHURA, J.
Given these conflicting claims, we must abide by the rule that where two certificates of title purport to include the same land, the earlier in date prevails.[15] Thus, without any legal or factual basis to lay claim over the land, petitioner had clearly no right to order respondents' eviction from the land.
2009-06-30
VELASCO JR., J.
Third, the Republic, relying on Metropolitan Waterworks and Sewerage System v. Court of Appeals,[13] contended that no new title over the subject lot can be issued in favor of the applicant, the same lot being already covered by a title, specifically OCT No. 2765 in the name of Lizares.
2007-12-14
TINGA, J,
The controversy attending the lands of OCT No. 994 has not eluded this Court. Since 1992, our findings and ruling in MWSS v. Court of Appeals[4] have stood as the Rosetta Stone in deciphering claims emanating from OCT No. 994, as was done in Gonzaga v. Court of Appeals, [5] and in the Court's Decision dated 29 November 2005 (2005 Decision) in these cases.[6] Yet in the course of resolving these motions for reconsideration came the revelation that OCT No. 994 was lost in translation following MWSS. Certain immutable truths reflected on the face of OCT No. 994 must emerge and gain vitality, even if we ruffle feathers in the process.
2006-09-26
TINGA, J.
Petitioners' reliance on Metropolitan Waterworks and Sewerage Systems (MWSS) v. Court of Appeals[9] and Director of Lands v. Court of Appeals[10] is misplaced. MWSS is a case of overlapping titles where the Court held that where two certificates of title purport to include the same land, the earlier date prevails. The principle in MWSS does not apply to the factual milieu of the instant case as the land registration court in LRC Case No. N-1175 squarely ruled that Lot No. 967 covered by the Avilas' OCT No. 1035 does not encroach upon petitioners' Lot No. 968. In MWSS, the party holding the earlier certificate of title was not a party to the subsequent registration proceeding and, thus, was not able to participate therein. Hence, the principle of res judicata could not be applied to the filing of a subsequent action for quieting of title.