Philippine Banking Corporation v. She
REITERATIONFacts
The Antecedents: The case involves a series of contracts between Philippine Banking Corporation, representing the estate of Justina Santos, and Lui She, administratrix of the estate of Wong Heng. These contracts included a 50-year lease agreement for Justina Santos' property, later amended to cover the entire property and extended to 99 years. Additionally, there was an option to buy the leased premises, initially conditional on Wong Heng's naturalization, and later extended. The Court previously declared these contracts void as they were part of a scheme to place ownership of land in the hands of an alien, violating the Constitution. Procedural History: The Supreme Court had previously rendered a decision on September 12, 1967, declaring the contracts void. The defendant-appellant filed a motion for reconsideration, which was denied. Subsequently, the defendant-appellant filed a motion for a new trial based on alleged newly-discovered evidence. The Appeal: The defendant-appellant sought a new trial based on three documents: a codicil dated November 11, 1957, and two wills executed on August 24 and August 29, 1959. These documents were claimed to be newly-discovered evidence that could alter the outcome of the case. The defendant-appellant argued that the codicil devised the property to Tita Yaptinchay Lao, suggesting Justina Santos did not intend to give ownership to Wong Heng, and that the wills showed a desire to abide by the law by linking Wong Heng's right to buy to his Filipino citizenship.
Issue(s)
Whether the codicil and wills constitute newly-discovered evidence warranting a new trial. Whether the alleged newly-discovered evidence would alter the Supreme Court's previous decision declaring the contracts void.
Ruling
The motion for a new trial is denied. The Supreme Court found that the documents presented were not newly-discovered evidence, as they were either already part of the records or known to the defendant-appellant and her counsel. Furthermore, even if considered, the documents would not alter the Court's previous conclusion that the contracts were void for violating the Constitution.
Ratio Decidendi
On Issue 1: The Court found that the documents presented by the defendant-appellant did not qualify as newly-discovered evidence. The two wills from 1959 were already presented as exhibits in the case and were explicitly mentioned in the lower court's and the Supreme Court's decisions. The codicil from 1957, while not formally presented as an exhibit, had its provisions substantially testified to by one of the defendant's witnesses and were recited in the lower court's decision. Therefore, the defendant could not claim ignorance of these documents or their essence, and they were discoverable with due diligence during the trial. The claim that these documents were presented in the probate court only after Justina Santos' death was deemed a misrepresentation, as they were known to the parties prior to the conclusion of the trial in this case. On Issue 2: The Court held that even if the alleged newly-discovered evidence were considered, it would not change the outcome of the case. Regarding the 1957 codicil, the Court noted that even if Justina Santos had devised the land to Tita Yaptinchay Lao, this did not preclude her from subsequently entering into contracts that effectively transferred ownership to Wong Heng. The execution of the lease contract and option to buy, amounting to a conveyance, would constitute an implied revocation of the codicil concerning the disposition of the land. As for the 1959 wills, the Court viewed the statement about Wong Heng's right to buy being contingent on his citizenship as a mere reiteration of the existing lease and option contracts, which the Court had already determined to be a conveyance in disguise, despite the protestation of compliance with the law. The Court also cited testimony from the defendant's own witnesses that Justina Santos was adamant about her wishes regarding Wong Heng and the properties, even acknowledging potential illegality but asserting her right to question it.
Main Doctrine
The Supreme Court reiterated that contracts designed to circumvent constitutional prohibitions against aliens owning land in the Philippines are void. Even a lease contract, when part of a larger scheme to effectuate such an unconstitutional transfer of ownership, is tainted with the same illegality. The Court also emphasized that documents known to the parties or discoverable with due diligence cannot be considered newly-discovered evidence to warrant a new trial.