El Banco Nacional Filipino v. Encarnacion Escudero; El Banco Nacional Filipino Vs. Domingo Ramos; El Banco Nacional Filipino Vs. Pacifico Lacsa

Summary

This consolidated case involves three property ownership disputes between El Banco Nacional Filipino and individual defendants over land parcels originally owned by Felix Silo. The central issue was the priority of rights between the bank's registered mortgage (1919, registered 1920) and subsequent unregistered sales to the defendants. Felix Silo had mortgaged the properties to the bank, then sold the same properties to various individuals without registering these sales. When the bank foreclosed and acquired the properties through judicial auction, the defendants claimed ownership based on their purchases from Silo. The Supreme Court reversed the trial court, applying Article 194 of the Revised Administrative Code and Article 1473 of the Civil Code to hold that the bank's registered interest had priority over the defendants' unregistered purchases. The decision established that registration under the special registry system gives superior rights over unregistered conveyances, and that defendants who failed to redeem the mortgage or exercise repurchase rights after judicial sale could not claim ownership through mere possession.