HALILI VS CA A.

BARTOLOME

Doctrine

If a 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.

Facts

- Simeon de Guzman, an American citizen, died in 1968, leaving real properties in the Philippines.

- Forced heirs:
Helen Meyers (widow), American
David Rey Guzman (son), American

- 9 Aug 1989: Helen executed a dead of quitclaim transferring to David all her rights, titles, and
interests over the inherited land (six parcels of land).

- 5 Feb 1991: David Rey sold one of the parcels of the land to Emiliano Cataniag, a Filipino

- Petitioners, owners of the adjoining lot, filed a complaint before the RTC Malolos questioning the
constitutionality and validity of the two conveyances. They claim ownership of the lands based on their
right of legal redemption under Art. 1621 of the Civil Code.

- RTC dismissed the complaint, and held:

Helen's waiver of her inheritance was not contrary to the constitutional prohibition against the sale of
land to an alien, since it was simply to authorize David Rey to dispose of their properties.

Subject land was urban, and cannot be redeemed under Art. 1621 of the Civil Code.

- CA affirmed the RTC decision. Furthermore, it cited Tejido v. Zamacoma and Yap v. Grageda and held:

Although the transfer of the land may have been invalid for being contrary to the Constitution,
petitioners may no longer recover the property as it was passed on to and now owned by a qualified
person.

Issues

1. WON the CA erred in concluding that the land in question is urban, and could not be redeemed
under Art. 1621 of the Civil Code.

2. WON the sale to Cataniag is valid.



Held/Ratio

1. Yes, it is urban land that cannot be redeemed under Art. 1621 of the Civil Code.

On the Nature of Land:
- The issue on whether the land in dispute is rural or urban is a factual question which is not reviewable
by the Supreme Court. The findings of the RTC, when affirmed by the CA, are binding upon the
Supreme Court.
- There is clear and convincing evidence to prove that the subject property is urban land (presence of
different kinds of establishments, factories, commercial stores, hospitals, etc.).

On the Right of Redemption:
- Art. 1621 of the Civil Code was invoked by the petitioners. It specifically states that the land to be
redeemed and the adjacent lot belonging to the person exercising the right of redemption must both
be rural. The language of the law is clear. The right to redemption cannot be invoked.

2. Yes, it is valid, for whatever constitutional infirmities that arose before the sale were rectified
upon the sale to a Filipino citizen.

On Foreign Ownership of Lands:
- It is true that the deed of quitclaim collided with Art. XII, Sec. 7 of the 1987 Constitution (Sec. 5, Art.
XIII of the 1935 Constitution), which states that except in cases of hereditary succession, no private
lands shall be transferred or conveyed except to individuals... qualified to acquire or hold lands of the
public domain.
- Krivenko v. Register of Deeds interpreted Sec. 1, Art. XIII of the 1935 Constitution (Sec. 2, Art. XII of
the 1987 Consti.) such that only Filipino citizens may own public agricultural lands. Read together with
Sec. 7, this means that only Filipinos are qualified to own both public and private lands.

Reading these two provisions together prevents the possibility that Filipino citizens may alienate their
agricultural lands in favor of aliens. All in all, non-Filipinos cannot acquire or hold title to private lands
or to lands of the public domain, except only by way of legal succession.

On the Transfer of Lands:
- 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. The sale can no longer be impugned on the basis of the invalidity of the initial transfer.
- Jurisprudence exists that support this holding (United Church Board of Word Ministries v. Sebastian,
de Castro v. Tan, etc.).