Republic v. Register of Deeds
REITERATIONFacts
The Antecedents: In March 1936, Lee Liong, a Chinese citizen, purchased Lot No. 398 from the Dinglasan siblings. Lee Liong died intestate in February 1944, survived by his widow and two sons. In 1947, the heirs extrajudicially settled the estate and partitioned Lot No. 398. Upon the death of the sons, the lot was transferred by succession to their respective wives, Elizabeth Lee and Pacita Yu-Lee (private respondents), who are Filipino citizens. Procedural History: Previous cases involving Lot No. 398, namely Dinglasan v. Lee Bun Ting (1956) and Lee Bun Ting v. Judge Aligaen (1967), established that the sale to Lee Liong was void for violating the constitutional prohibition on alien land ownership, but the sellers were barred by in pari delicto and res judicata from recovering the property. In 1993, private respondents sought reconstitution of title. In 1995, the Republic of the Philippines (petitioner) filed a Complaint for Reversion of Title, praying that the sale to Lee Liong be declared void and the lot reverted to the State. The Regional Trial Court ruled in favor of the State. The Court of Appeals reversed this decision, declaring private respondents as absolute owners. Petitioner's motion for reconsideration was denied. The Petition: Petitioner Republic of the Philippines seeks review of the Court of Appeals' decision, arguing that the Court of Appeals erred in declaring private respondents as owners, as Lee Liong, an alien, acquired no valid title that could be transmitted by succession.
Issue(s)
Whether the Court of Appeals gravely erred in reversing the trial court's decision and declaring private respondents the absolute and lawful owners of Lot No. 398, considering that the initial acquisition by Lee Liong, an alien, was constitutionally prohibited and thus void, AND whether the subsequent transfer of Lot No. 398 by succession to Filipino citizens cures the defect in the original sale to an alien, thereby precluding reversion proceedings by the State.
Ruling
The petition is denied. The Decision dated 12 July 2002 and the Resolution dated 9 May 2003 of the Court of Appeals in CA-G.R. CV No. 53890 are affirmed.
Ratio Decidendi
On the issue of whether the initial acquisition by an alien was void AND whether the subsequent transfer to Filipino citizens cures the defect: The Court held that the petition is without merit. While the sale of Lot No. 398 to Lee Liong, a Chinese citizen, was indeed void ab initio for violating the constitutional prohibition against alien ownership of land, the subsequent circumstances militate against reversion proceedings. Upon Lee Liong's death, the lot was settled and partitioned among his heirs, and subsequently transferred by succession to his sons' wives, Elizabeth Lee and Pacita Yu-Lee, who are Filipino citizens. The Court reiterated its ruling in De Castro v. Teng Queen Tan, where a similar situation involving land sold to an alien who later died, and the land was transferred to a naturalized Filipino, was sustained. The Court emphasized that the constitutional proscription against alien ownership was intended to keep lands in Filipino hands. In this case, the objective has been achieved as the land is now in the possession of qualified Filipino citizens. The flaw in the original transaction is considered cured, and the title of the transferee is deemed valid. Therefore, the subsequent transfer of the property to qualified Filipinos may no longer be impugned on the basis of the invalidity of the initial transfer. The Court also noted that the reversion proceedings were initiated almost 40 years after the Dinglasan case, by which time the property was already in the hands of Filipino citizens. If the State had commenced reversion proceedings when the land was still in the hands of the disqualified alien vendee, it would have been allowed. However, as the land is now owned by Filipino citizens, the reversion proceedings will no longer prosper.
Main Doctrine
The subsequent transfer of land, initially invalidly sold to an alien, to qualified Filipino citizens cures the flaw in the original transaction, achieving the constitutional objective of keeping lands in Filipino hands, and thus bars reversion proceedings.