Facts:

The case of Benito Arambulo vs. Ua So and Cua Po Chooh revolves around a dispute regarding the sale of two parcels of land located on Narra Street, Manila. The plaintiff, Benito Arambulo, a Filipino citizen, was the original owner of the properties, holding Transfer Certificate No. 59259 from the Manila Register of Deeds. On February 23, 1948, Arambulo sold these parcels to the defendants, Ua So and Cua Po Chooh, who are Chinese citizens. Shortly after the sale, on January 28, 1948, Arambulo initiated legal proceedings to revoke the sale and recover the properties, citing the Krivenko decision, which established that the Philippine Constitution prohibits the sale of urban lands to foreigners. The Manila Court of First Instance dismissed Arambulo's complaint, relying on the precedent set in Cabauatan vs. Uy Hoo, which ruled that the constitutional prohibition was not in effect during the Japanese occupation of the Philippines and that even if it were, the seller could not ...

Facts:

Ownership and Sale of Land: Before the Pacific War, Benito Arambulo, a Filipino citizen, owned two parcels of land located at Narra Street, Manila, evidenced by Transfer Certificate of Title No. 59259 issued by the Manila Register of Deeds. On February 23, 1948, Arambulo sold these parcels to the defendants, Ua So and Cua Po Chooh, who are Chinese citizens.

Legal Action: On January 28, 1948, Arambulo initiated proceedings to revoke the sale and recover the properties, citing the Krivenko decision. This decision declared that the Philippine Constitution prohibits the sale of urban lands to foreigners.

Lower Court Decision: The Manila Court of First Instance dismissed Arambulo’s complaint, relying on the ruling in Cabauatan vs. Uy Hoo (88 Phil., 103). The court held that: (1) during the Japanese occupation, the constitutional prohibition was not in force, and (2) even if it were, the seller could not recover the property because the law should not assist either party to an illegal transaction.

Appeal: Arambulo appealed, arguing that the Cabauatan ruling should be revised. He contended that the Constitution was in effect even during the Japanese occupation and that the prohibition against alien ownership required reconveyance of the property to him.

Issue:

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Ruling:

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Ratio:

1. Constitutional Prohibition During Occupation: The constitutional prohibition against the sale of urban lands to foreigners was not in force during the Japanese occupation. The Court maintained that the Japanese military administration did not suspend this provision, but even if it were applicable, the legal consequences would be the same due to the doctrine of in pari delicto.
2. In Pari Delicto Doctrine: The Court applied the principle that the law does not aid either party to an illegal transaction. Both the vendor and the vendees were equally at fault for violating the constitutional prohibition (if it were in force), and thus, the vendor could not recover the property.
3. Precedent Consistency: The Cabauatan ruling was consistently affirmed in subsequent cases, establishing a settled doctrine that denies recovery in similar situations.