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Question
Under NCC, Art. 8, judicial decisions form part of the law. In a dispute over a land title, X v. Y (G.R. No. 123456, 1995) held that a sale of land is valid even if the deed was not registered, as against the parties to the sale. In 2005, the legislature enacted a land registration statute requiring registration for validity against third parties. A current owner seeks to register a deed under the old rule; the Register of Deeds refuses, citing the new statute. (a) Identify the controlling doctrine under NCC, Art. 8 about the binding effect of judicial decisions. (b) Distinguish the binding effect of the 1995 decision on the parties to the present dispute and on the land registry. (c) Apply to the facts: Should the 2005 statute govern, or does the 1995 decision continue to bind? Explain the resolution under Art. 8 and the relationship between statutes and judicial decisions.