Case Digest (G.R. No. L-6801)
Facts:
Herbert Brownell, Jr., Attorney General of the United States, as successor of the Philippine Alien Property Administrator, Plaintiff and Appellant, vs. Macario Bautista, Defendant and Appellee, Republic of the Philippines, Intervenor and Appellant, G.R. No. L-6801, September 28, 1954, the Supreme Court En Banc, Bautista Angelo, J., writing for the Court.The Philippine Alien Property Administrator (the Administrator) issued Vesting Order No. P-394 (amended February 2 and July 14, 1949) purporting to vest in himself a one-half undivided interest in several parcels of land in Baguio and San Clemente, Tarlac, certain personalty (furniture and household equipment), a bank balance (P5,156.83), rents (P1,867.50) and insurance proceeds (P1,451.81). The Administrator claimed those portions belonged to Carlos Teraoka and Marie Dolores Teraoka, alleged nationals of Japan (enemy nationals). The Administrator demanded one-half of possession from Macario Bautista, who was then in possession; Bautista refused, asserting he was sole owner by inheritance as the surviving heir.
The Administrator filed suit in the Court of First Instance of Mountain Province for partition and delivery of one-half of the properties; Antonio Baluga was joined because he had purchased one parcel. The Republic of the Philippines was permitted to intervene and adopted the Administrator’s complaint. Bautista pleaded ownership as sole heir (except the lot sold to Baluga), expenditures made on the property, disputed the enemy-national status of the Teraokas (asserting Filipino nationality), contested the Administrator’s authority to vest non-enemy property, and argued that, if Carlos and Marie were enemy nationals, they were minors with future rights to elect Philippine citizenship.
The Administrator responded that his administrative determination of nationality and vesting was conclusive and not subject to review in that suit; aggrieved parties should pursue administrative claims under section 32 or judicial relief under section 9(a) of the Trading with the Enemy Act. After trial the lower court dismissed the Administrator’s complaint, finding the Administrator failed to prove Carlos and Marie were Japanese nationals, concluded they were Filipino citizens, held the vesting order illegal as to their interest, and protected Baluga as an innocent purchaser.
The Administrator and the Republic appealed to the Court of Appeals but sought transfer to the Supreme Court on the ground that only questions of law were involved; the transfer was granted. During the proceedings the Philippine Alien Property Administration was terminated (Executive Order No. 10254, effective June 29, 1951) and its functions transferred to the U.S. Attorney General; Herbert Brownell, Jr. was substituted as plaintiff by the lower court’s order of August 13, 1951. Because the case was transferred as presenting pur...(Pro-only)
Issues:
- May the Philippine Alien Property Administrator invoke Section 3 of the Philippine Property Act of 1946 to have Philippine courts enforce his vesting order and thereby preclude judicial inquiry into the validity of that vesting after Philippine independence?
- Was the action filed in the Court of First Instance an action under Section 3 of the Philippine Property Act (an enforcement/possession proceeding) or an action for partition under Rule 71 which permits the court to decide owne...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)