Arambulo v. Cua So
REITERATIONFacts
The Antecedents: Plaintiff, a Filipino citizen, sold two parcels of land to defendants, who are Chinese citizens, on February 23, 1943, before the Pacific War. The plaintiff sought to revoke the sale and recover the properties on January 28, 1948, invoking the Krivenko decision which declared that the Constitution forbids the sale of urban lands to foreigners. Procedural History: The Court of First Instance of Manila dismissed the complaint, applying the ruling in Cabauatan v. Uy Hoo, which held that the constitutional prohibition was not in force during the Japanese occupation, and even if it were, the seller could not recover because the law should not aid either party to an illegal transaction. The Petition: The plaintiff appealed, arguing that the Cabauatan ruling was erroneous, that the Constitution was obligatory even during the Japanese regime, and that the violation of the Constitution required reconveyance to the vendor.
Issue(s)
Whether a Filipino vendor can recover land sold to alien vendees in violation of the Constitutional prohibition against alien land ownership. Whether the Constitutional prohibition against alien land ownership was in force and binding during the Japanese occupation.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, dismissing the complaint. The Court reiterated its stance in Cabauatan v. Uy Hoo and subsequent cases, denying recovery to the Filipino seller.
Ratio Decidendi
On Issue 1: The Court held that the vendor is barred from recovery by the doctrine of 'in pari delicto'. Applying the precedent in Cabauatan v. Uy Hoo, the Court explained that even if the sale violated the Constitution, the law should not help either party to an illegal transaction. This doctrine has been consistently reaffirmed in Ricamara v. Ngo Ki, Rellosa v. Gaw Chee Hun, and Caoile v. Yu Chiao. The Court emphasized that the parties entered into the contract voluntarily, and the seller cannot now invoke the illegality of his own act to regain the property. The refusal to annul the conveyance is a consequence of the parties being in equal fault, where the law leaves them as it finds them. Consequently, the Filipino vendor has no cause of action for reconveyance against the alien vendee. On Issue 2: The Court implicitly acknowledged that even if the Constitutional prohibition was binding during the Japanese regime, it would not change the outcome for the vendor. The dismissal was predicated on the 'in pari delicto' rule which operates regardless of whether the prohibition was in force, as the act of selling to an alien was the illegal act the plaintiff participated in. The Court noted that the Cabauatan ruling specifically addressed conveyances made in March 1943, during the occupation, and found recovery unavailable. Thus, the temporal context of the Japanese occupation does not exempt the transaction from the application of established civil law principles regarding illegal contracts. The stability of the doctrine was prioritized over the appellant's request for a revision of the ruling.
Main Doctrine
The doctrine established in Cabauatan v. Uy Hoo, which denies recovery to Filipino citizens who sold urban lands to Chinese aliens during the Japanese occupation, has been affirmed and reaffirmed in subsequent cases, even if the sale violated the constitutional prohibition against alien ownership of urban lands.