Professional Documents
Culture Documents
Liao v. CA, G.R. Nos. 102961-62. January 27, 2000
Liao v. CA, G.R. Nos. 102961-62. January 27, 2000
property through sale certificates Nos. 780, 781, 783, issued by the
Director of Lands in 1913. These sales were void because the sales
were not approved by the Secretary of Agriculture and Natural
Resources even if the sale certificates were signed by the Director of
Lands and approved by the Secretary of the Interior. Approval by
the Secretary of Agriculture and Commerce is indispensable for the
validity of the sale of friar lands. In the absence of such approval,
the sales were void.
Assuming their validity the sale certificates became stale after ten
(10) years from its issuance. They cannot be the source documents
for issuance of title more than seventy (70) years later.
b. Double Sale
Faced with a situation where both parties claim to have acquired the
subject property, the law provides that as between two purchasers,
the one who registered the sale in his favor has a preferred right
over the other who has not registered his title, even if the latter is
in actual possession of the immovable property. wvirtualibräry