Short answer. Yes, as to later credits. Article 2242 lists credits annotated in the Registry of Property by virtue of a judicial order, through attachments or executions, as preferred upon the property affected, but only as to later credits. Your registered attachment gives you priority over creditors whose claims came after it.
What the law says
(7) Credits annotated in the Registry of Property, in virtue of a judicial order, by attachments or executions, upon the property affected, and only as to later credits
Civil Code, Article 2242 — Preferred Credits on Specific Immovables. Read the full provision →
Your registered attachment is a preferred credit on this land
Article 2242 lists several kinds of claims that are preferred with reference to specific immovable property, and item seven covers exactly your situation: credits annotated in the Registry of Property, in virtue of a judicial order, by attachments or executions, upon the property affected, and only as to later credits. Because your attachment was annotated on the land by virtue of a judicial order, it falls within this category, and the law treats it as an encumbrance on that specific immovable that carries a real preference over certain other claims.
The preference reaches forward, not backward
The phrase only as to later credits is the key limitation built into this provision. Your registered attachment is preferred over creditors whose claims arose or were registered after your attachment was annotated, which answers your question directly. It does not, by its own terms, give your attachment priority over credits that already existed or were already recorded before your attachment was annotated. The preference this article grants runs forward in time from the date of annotation, protecting you against later claimants rather than reordering claims that came before you.
Why registration and timing both matter
The list in Article 2242 groups together several different kinds of preferred claims on immovable property, from unpaid taxes to mortgage credits to claims of workmen who built on the property, each attached to the specific real property involved. For an attachment or execution credit specifically, the law ties the preference to the act of annotation in the Registry of Property, which is why the timing of your registration relative to other creditors' claims is what determines whether you come ahead of or behind them under this rule.
What this means in a dispute among creditors
If multiple creditors are asserting claims against the same parcel of land, your position relative to each one depends on comparing when your attachment was annotated against when each other credit arose or was registered. Creditors whose claims came later than your annotation rank behind you under Article 2242, while creditors whose claims predate your attachment are not automatically subordinated to you by this provision alone. Establishing the precise dates involved is central to working out where each claim actually stands in relation to the others.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Atlantic Erectors, Inc. vs. Herbal Cove Realty Corporation, G.R. No. 148568, March 20, 2003 — read the decision on LawPhil →
- Jan-Dec Construction Corporation vs. Court of Appeals, et al, G.R. No. 146818, February 6, 2006 — read the decision on LawPhil →
- J.L. Bernardo Construction, et al. vs. Court of Appeals, et al, G.R. No. 105827, January 31, 2000 — read the decision on LawPhil →
- Strategic Alliance Development Corporation vs. Radstock Securities Limited and Philippine National Construction corporation, G.R. No. 178158 / G.R. No. 180428, December 4, 2009 — read the decision on LawPhil →