Registration of Unregistered Land

Under Act No. 3344, registration of instruments affecting unregistered lands is ‘without prejudice to a third party with a better right.’ The aforequoted phrase has been held by this Court to mean that the mere registration of a sale in one’s favor does not give him any right over the land if the vendor was not anymore the owner of the land having previously sold the same to somebody else even if the earlier sale was unrecorded (Spouses Celemencio C. Sabitsana, Jr. and Ma. Rosario M. Sabitsana Vs. Juanito F. Muertegui, represented by his attorney-in-fact, Domingo A. Muertegui, Jr., G.R. No. 181359. August 5, 2013).