Alien Individuals may be transferees of private lands only in cases of hereditary succession.

(Sec. 7, Article XII, Constitution)

PBCom v. Lui She
Taken singly, the lease contracts show nothing that is necessarily illegal, but considered
collectively, they reveal an insidious pattern to subvert by indirection the Constitutional
prohibition of Alien ownership of land. To be sure, a lease to an alien for a reasonable period is
valid. So is the option giving an alien the right to buy real property on condition that he is
granted Philippine citizenship.
But if an alien is given not only a lease, but also an option to buy, a piece of land, by virtue of
which the Filipino owner cannot sell or otherwise dispose of his property, this is to last for 50
years, then it becomes clear that the arrangement is a virtual transfer of ownership whereby
the owner divests himself in stages not only of the right to enjoy the land but also of the right
to dispose of it rights the sum total of which make up ownership.
Court held all lease contracts void because of the intent surrounding the execution.
Ramirez v. Vda. de Ramirez
The device [testamentary succession] of a usufruct to an alien who is not a legal heir does not
vest title to the land in the usufructuary. It is not prohibited by the Constitution because it is
the vesting of title to land in favor of aliens which is proscribed by the Constitution.
The Constitutional provision which enables aliens to acquire private lands does not extend to
testamentary succession otherwise any alien would be able to circumvent the prohibition by
paying money to a Philippine landowner in exchange for a devise of a piece of land.
Cheesman v. IAC
Constitution prohibits the sale to aliens of residential land. Cheesman was charged with
knowledge of this prohibition. Thus, assuming that it was his intention that the lot in question
be purchased by him and his wife, he acquired no right whatever over the property by virtue of
that purchase; and in attempting to acquire a right or interest in land, vicariously and
clandestinely, he knowingly violated the Constitution; the sale as to him was void.
In any event, he had and has no capacity or personality to question the subsequent sale of the
same property by his wife on the theory that in so doing he is merely exercising the prerogative
of a husband in respect of conjugal property.
To sustain such a theory would permit indirect violation of the Constitution. If the property
were to be declared conjugal, this would accord to the alien husband a substantial interest and
right over the land, as he would then have a decisive vote as to its transfer or disposition. This is
a right which the Constitution does not permit him to have.

As already observed, the finding that his wife had used her own money to purchase the
property cannot, and will not, at this stage of the proceedings be reviewed and overturned. But
even if it were a fact that said wife had used conjugal funds to make the acquisition, the
considerations just set out militate, on high constitutional grounds, against his recovering and
holding the property so acquired or any part thereof. And whether in such an event, he may
recover from his wife any share of the money used for the purchase or charge her with
unauthorized disposition or expenditure of conjugal funds is not now inquired into; that would
be, in the premises, a purely academic exercise
Muller v. Muller
(Note: academic in cheesman was realized here]
Mr. Muller was aware of the Constitutional prohibition when he purchased the property. He
declared the property in the name of Mrs. Muller because of said prohibition. His attempt at
subsequently asserting or claiming a right on the said property cannot be sustained.
There was no implied trust created. Save for hereditary succession, an aliens disqualification is
absolute. Not even an ownership in trust is allowed. Besides, no trust can result in favor of the
party who is guilty of the fraud. To hold otherwise would allow a circumvention of the
constitutional prohibition.
He who seeks equity must do equity, and he who comes into equity must come with clean
hands. Mr. Muller cannot seek reimbursement of the funds he used to purchase the property
on the ground of equity where it is clear that he willingly and knowingly bought the property
despite the constitutional prohibition.
Ting Ho v. Teng Gui
The subject lot does not form part of the Estate of the deceased alien who was absolutely
prohibited from owning land. By virtue of the miscellaneous sales patent and the corresponding
OCT issued in his name Teng Gui is considered the owner of the land.
Moreover, the prohibition against an alien owning lands of the public domain is absolute and
not even an implied trust can be permitted to arise on equity considerations.
However, the properties erected on the land owned by Teng Gui form part of the estate of
respondents deceased father.
(Note: ownership over the land separated from the building/improvement.)