Facts:

The case revolves around an ownership dispute related to a parcel of land in San Juan, Rizal, owned by Dolores D. Alberto, the plaintiff and appellee, as of June 1945. On June 21 of that year, Alberto sold the land to Tan C. Sing, a Chinese citizen, and his wife Dee Bun, the defendants and appellees, for a price of P20,000. Subsequently, on April 7, 1947, Tan C. Sing conveyed the same property to Alexandra Y. de Pascual, who is married to Ramon Pascual, both of whom are Filipino citizens, for a purchase price of P24,000. On January 8, 1948, Dolores D. Alberto initiated legal action against the Sing spouses, seeking to annul the sale on the grounds that they were Chinese citizens, thereby disqualified by the Philippine Constitution from acquiring private agricultural lands. The Pascuals intervened, contesting the legality of the annulment of their property acquisition. The Court of First Instance of Manila ultimately annulled both sales, asserting that Tan C. Sing had obtained no

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Facts:

Background and Transaction History

• In June 1945, Dolores F. Alberto, the owner of a parcel of land with improvements in San Juan, Rizal, sold the property for ₱20,000.00 to Tan C. Sing, a Chinese citizen; his wife, Dee Bun, is also implicated as a defendant.
• On April 7, 1947, Tan C. Sing conveyed the same parcel to Alexandra Y. de Pascual, who is married to Ramon Pascual, a Filipino citizen, for a purchase price of ₱24,000.00.

Initiation of Litigation

• On January 8, 1948, Dolores F. Alberto filed a case against Tan C. Sing and Dee Bun seeking to annul the sale on the ground that, under the Philippine Constitution, Chinese citizens are disqualified from acquiring private agricultural lands.
• Ramon Pascual and his wife intervened in the suit, defending the legality of their subsequent acquisition of the property.

Proceedings in the Lower Court

• The court of first instance in Manila annulled both transfers. It held that, under the precedent set in the Krivenko decision, Tan C. Sing acquired no valid right to the land and, consequently, conveyed none to the Pascual spouses.
• The decision was driven by the constitutional prohibition against foreigners acquiring agricultural land and the doctrine of in pari delicto, meaning both sides were equally at fault under the law.

Arguments Raised by the Parties

• The intervenors-appellants (the Pascuals) argued that even if the sale from Alberto to Tan C. Sing was invalid, the seller could not reclaim the property because it had been subsequently transferred to Filipino citizens.
• Their legal team maintained that when a foreigner acquires land in contravention of the Organic Act, he may hold title against all persons (except the State) and can dispose of his interest; thus, his grantees or devises would acquire title notwithstanding his alien status.

Submission of Authorities

• References were made to related cases (e.g., Krivenko decision, Cortes v. O Po Poe, Rellosa v. Gaw Chee Hun, and Caoile v. Yu Chiao) emphasizing that the seller of property to a disqualified foreigner cannot recover the property if it has already been transferred.
• Additionally, a Spanish Supreme Court ruling was cited, suggesting that while the sale is null and void, the seller might only recover the property through restitution of the price to “restore the virtuality of the constitutional prohibition.”

Issue:

Validity of the Initial Sale

• Is the sale of the land from Dolores F. Alberto to Tan C. Sing valid despite the constitutional prohibition on land acquisitions by Chinese citizens?
• Can the subsequent conveyance from Tan C. Sing to Alexandra Y. de Pascual be upheld even though it originated from an invalid sale?

Rights to Revert the Sale

• Does Dolores F. Alberto, as the original owner, have a right to recover the property sold in 1945 despite it being subsequently transferred to Filipino citizens?
• How does the doctrine of in pari delicto affect her claim to annul the sale and reclaim the property?

Applicability of Precedents

• To what extent do the precedents (particularly the Krivenko decision and other cited cases) govern the validity of a sale executed by a disqualified foreigner?
• What legal mechanisms are available for the seller if the sale is deemed null yet the property has changed hands?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)