Halili v.

CA

Civil Law. Sales. Transfer of interest (piece of land) to an alien.

Celso R. Halili & Arthur R. Halili v. CA, Helen Meyers Guzman, David Rey Guzman and
Emiliano Cataniag
G.R. No. 113539, March 12, 1998
Panaganiban, J..:

FACTS:
Petitioners appealed from the decision of the MTC and RTC ruling that Helen Guzmans
(American citizen) waiver of her inheritance in favor of her son was not contrary to the
constitutional prohibition against the sale of land to an alien.

Simeon de Guzman, an American citizen, died sometime in 1968, leaving real properties in
the Philippines. His forced heirs were his widow, defendant appellee Helen Meyers Guzman,
and his son, defendant appellee David Rey Guzman, both of whom are also American
citizens. 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. Subsequently, David Rey Guzman sold said parcel of land to
defendant-appellee Emiliano Cataniag.

Petitioners, who are owners of the adjoining lot, filed a complaint questioning the
constitutionality and validity of the two conveyances and claiming ownership thereto based
on their right of legal redemption under Art. 1621[5] of the Civil Code.

ISSUES:

1. Were the petitioners entitled to a right of redemption?

2. Was the sale of the lot to defendant-appellee Cataniag valid?

HELD:

1. NO. The petitioners were not entitled to a right of redemption. The subject
land is urban. Thus, petitioners have no right to invoke Art. 1621 of the Civil Code,
which presupposes that the land sought to be redeemed is rural.

2. YES. The sale to Cataniag is valid. Non-Filipinos cannot acquire or hold title
to private lands or to lands of the public domain. But what is the effect of a
subsequent sale by the disqualified alien vendee to a qualified 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. Since
the disputed land is now owned by Private Respondent Cataniag, a Filipino citizen,
the prior invalid transfer can no longer be assailed. The objective of the constitutional
provision -- to keep our land in Filipino hands -- has been served.