Simeon de Guzman, an American citizen, died sometime in 1968, leaving real
properties in the Philippines. His forced heirs were his widow private respondent Helen
Meyers Guzman, and his son, private respondent David Rey Guzman, both of whom
are also American citizens. On August 9, 1989, Helen executed a deed of quitclaim,
assigning, transferring and conveying to David Rey all her rights, titles and interests in
and over six parcels of land which the two of them inherited from Simeon.
Among the said parcels of land is that now in litigation Guzman then sold the
parcel of land to Catanaig, who is one of respondents in this case. Petitioners, who are
owners of the adjoining lot, filed a complaint before the Regional Trial Court of Malolos,
Bulacan, questioning the constitutionality and validity of the two conveyances —
between Helen Guzman and David Rey Guzman, and between the latter and Emiliano
Cataniag — and claiming ownership thereto based on their right of legal redemption
under Art. 1621 of the Civil Code. The trial court dismissed the complaint. The CA
denied the appeal of the Halilis.
ISSUE: Whether or not the sale of the land is null and void.
No, because the prohibition in the constitution has already been served. Article
XII, Section 7 provides that Non- Filipinos cannot acquire or hold title to private lands or
to lands of the public domain, In fine, non-Filipinos cannot acquire or hold title to private
lands or to lands of the public domain, except only by way of legal succession. While it
is true that the transfer of Helen of his right to her son who is an American citizen
contradicts the prohibition set forth in the Constitution, the Supreme Court upheld the
subsequent sale of the land to Catanig, a Filipino citizen. Jurisprudence is consistent
that “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 rationale of this principle was explained in Vasquez vs. Li Seng Giap thus
“If the ban on aliens from acquiring not only agricultural but also urban lands, as
construed by this Court in the Krivenko case, is to preserve the nation’s lands for future
generations of Filipinos, that aim or purpose would not be thwarted but achieved by
making lawful the acquisition of real estate by aliens who became Filipino citizens by
naturalization. “
Petition was denied.
