The Supreme Court ruled that while aliens are constitutionally prohibited from owning private agricultural lands in the Philippines, subsequent transfer of such lands to Filipino citizens cures the defect of the original transaction. This decision clarifies that the constitutional objective of keeping lands in Filipino hands prevails when the land is eventually held by qualified Filipino citizens, preventing its reversion to the State despite the initial illegal sale to an alien. The Court also emphasized that reconstitution of title cannot be based solely on a plan and technical description, as it requires more substantial evidence of the original title.

From Alienation to Filipino Hands: Can Land Illegally Sold Revert to the State?

The case of Elizabeth Lee and Pacita Yu Lee v. Republic of the Philippines revolves around a parcel of land originally sold to Lee Liong, a Chinese citizen, in 1936. This sale occurred during the effectivity of the 1935 Constitution, which prohibited aliens from acquiring private agricultural lands, except through hereditary succession. The core legal question is whether the Republic can recover the land, given the constitutional restriction and the subsequent transfer of the land to Filipino citizens. The outcome hinges on the interplay between constitutional law, property rights, and the legal principle of pari delicto.

The factual history of the case is complex. After the sale to Lee Liong, the original owners, the Dinglasans, twice attempted to annul the sale. The first attempt was rejected based on the doctrine of pari delicto, which prevents parties equally at fault from seeking legal remedies against each other. The Supreme Court in the first case stated:

“… granting the sale to be null and void and can not give title to the vendee, it does not necessarily follow therefrom that the title remained in the vendor, who had also violated the constitutional prohibition, or that he (vendor) has the right to recover the title of which he has divested himself by his act in ignoring the prohibition. In such contingency another principle of law sets in to bar the equally guilty vendor from recovering the title which he had voluntarily conveyed for a consideration, that of pari delicto.”

A second attempt was dismissed on the ground of res judicata, preventing the same issue from being relitigated. Years later, Elizabeth Lee and Pacita Yu Lee, widows of Lee Liong’s heirs, filed a petition for reconstitution of the title after the original records were destroyed during World War II. The Regional Trial Court granted the reconstitution. However, the Solicitor General filed a petition for annulment of judgment, arguing that Lee Liong, as an alien, could not legally own the land.

The Court of Appeals sided with the Solicitor General, declaring the judgment of reconstitution void. The Supreme Court, however, reversed the Court of Appeals’ decision. It acknowledged that the initial sale to Lee Liong was indeed a violation of the 1935 Constitution. The Court emphasized that aliens were disqualified from acquiring private agricultural lands. The pertinent provision of the 1935 Constitution states:

“Article XIII, Section 5, 1935 Constitution: aliens could not acquire private agricultural lands, save in cases of hereditary succession.”

Building on this principle, the Supreme Court stated that while the sale to Lee Liong was unconstitutional, the situation had changed significantly. Lee Liong had passed away, and the land had been inherited by his heirs, who are now Filipino citizens. The constitutional proscription on alien ownership aims to prevent land from falling into the hands of non-Filipinos. Because the land is now held by Filipinos, the original violation is considered cured.

The Court cited United Church Board of World Ministries v. Sebastian, stating, “If land is invalidly transferred to an alien who subsequently becomes a citizen or transfers it to a citizen, the flaw in the original transaction is considered cured and the title of the transferee is rendered valid.” This ruling underscores that the ultimate objective of the constitutional provision is to keep land in Filipino hands, a goal that has now been achieved. The Court further clarified that:

“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 objective of the constitutional provision to keep our lands in Filipino hands has been achieved.”

However, the Supreme Court noted a critical procedural flaw in the reconstitution process. The reconstitution of title was based solely on the plan and technical description approved by the Land Registration Authority, which is insufficient. The Court emphasized that reconstitution must be based on an owner’s duplicate, secondary evidence, or other valid sources of the title. Citing Heirs of Eulalio Ragua v. Court of Appeals, the Supreme Court reiterated this requirement, emphasizing the need for substantial evidence to support the reconstitution.

This procedural lapse rendered the order of reconstitution void. According to the Supreme Court, a judgment lacking factual support is invalid. Although the petitioners possessed the land, the issue of ownership necessitates a separate proceeding. The Court clarified that the purpose of reconstitution is merely to re-establish a lost or destroyed title; it does not adjudicate ownership.

The Supreme Court further discussed the possibility of reversion or escheat of the land to the State. Although the doctrine of pari delicto prevents the original sellers from reclaiming the land, the Solicitor General could theoretically initiate an action for reversion. However, the Court acknowledged that such proceedings might be untenable given that the land is now in the hands of Filipino citizens. Despite this possibility, the Court dismissed the petition for reconstitution without prejudice.

FAQs

What was the key issue in this case?	The key issue was whether land initially sold to an alien in violation of the 1935 Constitution could be subject to reversion to the State, despite now being held by Filipino citizens.
What is the doctrine of pari delicto?	The doctrine of pari delicto prevents parties who are equally at fault in an illegal transaction from seeking legal remedies against each other. In this case, it prevented the original sellers from reclaiming the land.
Why was the initial sale to Lee Liong considered illegal?	The initial sale to Lee Liong was illegal because he was a Chinese citizen, and the 1935 Constitution prohibited aliens from owning private agricultural lands in the Philippines.
What is the significance of the petitioners being Filipino citizens?	The fact that the petitioners are Filipino citizens is significant because the constitutional objective of keeping land in Filipino hands is achieved, curing the defect of the initial illegal sale.
What did the Court say about the reconstitution of title?	The Court clarified that the reconstitution of title does not determine ownership and must be based on reliable sources, such as an owner’s duplicate or secondary evidence, not solely on a plan and technical description.
Can the State still initiate an action for reversion of the land?	Theoretically, the State can initiate an action for reversion, but the Court acknowledged that such proceedings might be untenable since the land is now held by Filipino citizens.
What was the final ruling of the Supreme Court?	The Supreme Court reversed the Court of Appeals’ decision but set aside the order of reconstitution and dismissed the petition without prejudice, due to the flawed reconstitution process.
What is the practical implication of this ruling?	The practical implication is that land initially illegally sold to an alien can remain with Filipino heirs, as long as the land is in Filipino hands, but the title reconstitution process must follow proper procedures.

In conclusion, while the case initially presented a constitutional issue regarding alien land ownership, the subsequent acquisition of the land by Filipino citizens effectively cured the defect, aligning with the constitutional objective of preserving land for Filipinos. However, the decision also serves as a reminder of the strict requirements for land title reconstitution, emphasizing the need for reliable evidence to support such proceedings.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Elizabeth Lee and Pacita Yu Lee vs. Republic of the Philippines, G.R. No. 128195, October 03, 2001