Question

Civil

Rodrigo owned a parcel of land in Batangas City registered under the Torrens system and covered by Transfer Certificate of Title No. T-12345 in the Registry of Deeds. On March 1, 2023, Rodrigo executed a notarized deed of absolute sale conveying the land to Crisanto for PHP 5,000,000.00. Crisanto paid the full purchase price on the same date but did not register the deed of sale or obtain a new Transfer Certificate of Title in his name. On April 15, 2023, Rodrigo sold the same parcel of land again to Porfirio for PHP 4,800,000.00. Porfirio had no knowledge of the prior sale to Crisanto. Porfirio immediately registered the deed of sale and obtained Transfer Certificate of Title No. T-99876 in his name. Crisanto filed an action to recover the land from Porfirio, arguing that his purchase on March 1, 2023 was prior in time. Who has a better right over the property? (Bar 2026 Syllabus)

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