RULE IN CASE OF DOUBLE SALE
> Where two or more TCT are issued to different persons for the same lots, or subdivisions thereof, due to the fact that the original title was not cancelled when the first TCT was issued to replace the original title, which title prevails?
> General rule is that in case of 2 certificates of title purporting to include the same land, the earlier in date prevails, whether the land comprised in the latter certificate be wholly or only in part, comprised in the earlier certificate
> Where 2 certificates of title purport to include the same land, the earlier in date prevails. In successive registrations, where more than 1 certificate is issued in respect of a particular estate or interest in land, the person claiming under the prior certificate is entitled to the estate or interest; and the person is deemed to hold under the prior certificate who is the holder of, or whose claim is derived directly or indirectly from the person who was the holder of the earliest certificate issued in respect thereof.
> The vendee of the earlier certificate would be the owner as against the vendee of the owner of the latter certificate
REMEDY OF AGGRIEVED PARTY
> The purchaser from the owner of the later certificate and his successors, should resort to his vendor for redress, rather than molest the holder of the first certificate and his successors, who should be permitted to rest secure in their title.