G.R. No. 14918 - Government of the Philippine Islands vs. Zamora

On January 27, 1908, Domingo Zamora purchased from the Government a small parcel of land, later alleged to be Lot No. 9.
Subsequently, on July 12, 1913, Domingo Zamora secured a certificate of title under the Torrens system for Lot No. 9.
On the same day, January 27, 1908, Fausta Santo Domingo purchased from the Government a parcel of land, later alleged to be Lot No. 10.
Fausta Santo Domingo similarly obtained a certificate of title under the Torrens system for Lot No. 10 on July 12, 1913.

In a cadastral case initiated in the Court of First Instance of Rizal (Cadastral Case No. 3, G. L. R. O. Rec. No. 107), Domingo Zamora and Fausta Santo Domingo opposed the registration of certain parts of their Lots, claiming that the certificates of title already issued to them were conclusive.
Maria Concepcion Martinez Canas de Reguera contended that the certificates of title for Lots 9 and 10 omitted a strip along the southern boundary that belonged to her, forming an integral part of the Payatas Estate.
Specifically, she claimed that the contentious portion of Lot No. 9 measured 1 hectare, 78 ares, and 28 centares, and that of Lot No. 10 measured 3 hectares, 37 ares, and 88 centares.

Reguera based her claim on the prior issuance of Certificate of Title No. 333 on January 31, 1905, asserting that she was the first registrant of the disputed strip of land.
Her argument rested on the principle that an earlier registration prevails over later certificates of title within the overlapping portions of land.

The lower court (Court of First Instance of Rizal) rendered a decision favoring Maria Concepcion Martinez Canas de Reguera, upholding her claim over the disputed parcels.
Dissatisfied with this decision, Domingo Zamora and Fausta Santo Domingo appealed the ruling before the Supreme Court.
The Supreme Court reviewed the evidence, particularly emphasizing that the disputed strips were indeed registered in Reguera’s name several years before the appellants obtained their titles.

Whether the disputed strips along the southern boundaries of Lots 9 and 10 had been validly registered under the Torrens system in the name of Maria Concepcion Martinez Canas de Reguera prior to the issuance of the appellants’ certificates of title.
Whether the earlier registration of these strips by Reguera precluded the rights of Domingo Zamora and Fausta Santo Domingo over those portions, despite their possession of certificates of title for the remainder of the lots.

In the event that two certificates of title cover overlapping areas, the issue is to determine which title must prevail, particularly under the doctrine of priority in successive registrations.
The issue further involves whether the conclusive nature of a registration under the Torrens system protects an earlier certificate against a subsequent one when conflicting interests arise.