CASE TITLE: Oliveros vs San Miguel Corporation

GR # & DATE: GR 173531, February 1, 2012

TOPIC: Other specific rights found in Civil Code - Presumption of ownership

Facts:

Ramitex bought the subject property from co-owners Tomas Soriano (Soriano) and
Concepcion Lozada (Lozada) in 1957 and TCT No. T-18460 was issued on March 6, 1957 in favor
of Ramitex. Ramitex consolidated and subdivided its 17 lots within the Malinta Estate into six
lots. By virtue of this consolidation, the Register of Deeds of Caloocan City cancelled Ramitex’
individual title to Lot 1131 (TCT No. T-18460) and issued a new title, TCT No. T-137261.

Troubles began for Ramitex on February 22, 1989, when Oliveros filed a petition for the
reconstitution of TCT No. T-17186, his alleged title over Lot 1131 of the Malinta Estate. He
claimed that the original copy was destroyed in the fire that gutted the office of the Bulacan RD
on March 7, 1987.

Oliveros filed a complaint for the declaration of nullity of Ramitex’ title over Lot 1131 on.
claiming that he bought the subject property sometime in November 1956 from the spouses
Domingo De Leon and Modesta Molina, and pursuant to such sale, the Bulacan RD issued TCT
No. T-17186 in his favor on November 14, 1956.

Issue: Whether or not SMC’s title is void being the later title.

Held:

No, SMC’s title is not void. 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, "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.

Petitioners have not offered a reason or pointed to evidence that would justify overturning
this finding. Neither did they assert that this factual finding is unsubstantiated by the records.
Without a title, petitioners cannot assert priority or presumptive conclusiveness.