Concordia Astorga v. Court of Appeals

Summary

This property dispute involved competing ownership claims over a 300-square meter lot in Tacloban City. Froilan Montaño claimed ownership through a 1956 purchase registered in 1968 under TCT No. T-3917, while the Astorga spouses claimed ownership through a 1972 purchase registered as TCT No. T-8488. The Supreme Court applied Article 1544 of the Civil Code and ruled in favor of the Astorgas, finding they were the first to register their sale in good faith. The Court found Montaño's title spurious, noting it was based on an unnecessary administrative reconstitution of an OCT that was never actually lost, and that the issuance of Montaño's title was never properly noted in the original certificate. The decision established the principle that under the Torrens system, proper registration in good faith prevails over earlier but improperly registered claims.