Facts:

• On October 4, 1930, Miguel Paterno, as principal, and Domingo Madrilejo, Manuel Madrinal, and Leon Samson, as sureties, executed a bond for P5,000 in favor of the municipality of Caloocan, Province of Rizal.
• The bond guaranteed the payment of license fees for a cabaret or dance hall in Lerma, barrio of Maypajo, Caloocan, for the fourth quarter of 1930, the years 1931 and 1932, and the first three quarters of 1933.
• The bond stipulated joint and several liability for the payment of these fees.
• Paterno failed to pay the municipal license fee for the first quarter of 1931.
• The provincial fiscal of Rizal, on behalf of the municipal treasurer of Caloocan, filed a lawsuit on May 16, 1931, in the Court of First Instance of Rizal (Civil Case No. 4781) against Paterno, Madrinal, and Madrilejo to recover the unpaid amount.
• The court ruled in favor of the plaintiff, ordering the defendants to pay P1,250 with legal interest from May 16, 1931.
• The Supreme Court upheld this decision in Villegas vs. Paterno (G.R. No. 38936 [58 Phil, 978]), ensuring both the principal and sureties were jointly and severally liable.
• When the judgment was executed, a writ of execution was issued against the properties of Manuel Madrinal.
• On January 18, 1934, the sheriff attached all of Madrinal's interest in a piece of land described in Transfer Certificate of Title No. 12141, co-owned with Maximo Madrinal.
• This attachment was noted on January 24, 1934.
• On May 2, 1931, Maximo and Manuel Madrinal sold the land to Simeon Rael, reserving their right to redeem it within two years.
• This sale was recorded on February 19, 1934.
• After the two-year period expired, Rael consolidated his ownership, noted in Transfer Certificate of Title No. 12141.
• The registrar of deeds canceled this certificate and issued Transfer Certificate of Title No. 25437 in Rael's favor.
• The registrar also noted the attachment in favor of the municipality of Caloocan and a certificate of sale issued by the sheriff to the provincial government of Rizal on February 10, 1934, recorded on August 26, 1935.
• On September 11, 1935, Rael filed a motion to cancel the attachment and sale notations on his title, claiming he was the absolute owner free from encumbrances.
• The provincial government of Rizal opposed, asserting its superior right to the land.
• The lower court denied Rael's motion, leading to his appeal.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court affirmed the lower court's decision, denying Rael's motion to cancel the liens.
2. The Supreme Court also affirmed the lower court...(Unlock)

Ratio:

• The Supreme Court based its decision on Section 50 of Act No. 496, which states that a deed of conveyance is merely an authority for the registrar to proceed with its registration, and it is the act of registration that gives validity to the deed and affects the registered pro...continue reading