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Under NCC Art. 8, judicial decisions interpreting or applying laws form part of the law. In 2012, the Supreme Court held in Santos v. Dizon that a deed of sale of land between A (seller) and B (buyer) is valid and enforceable even if the deed is not annotated on the title. In 2020, Congress enacted a statute requiring annotation of deeds of sale on the title to affect rights against third parties. In 2024, C, not a party to Santos v. Dizon, seeks to register the 2012 deed against D’s title in the land registry. The Register of Deeds refuses, citing the 2020 statute. Explain: (i) which law governs for purposes of registration; (ii) whether the 2012 decision continues to bind A and B personally and whether it binds D’s title; and (iii) how Art. 8 governs the relation between judicial decisions and statutes in this context.

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The 2012 decision continues to bind the title vector because it interpreted a law; the 2020 statute cannot modify that. Registration should be governed by a hybrid rule: the 2020 statute controls third-party effects, while the 2012 decision controls the relationship between A and B; the registrar should apply both depending on the element involved. The governing law for purposes of registration is the 2020 statute; the 2012 decision remains binding only between A and B and does not bind D’s title; Art. 8 recognizes judicial decisions as part of the law but statutes prevail for third-party rights. The governing law for purposes of registration is the 2012 decision; the 2020 statute does not apply to registrations, so the deed may be registered against D’s title.

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