G.R. No. 201151 - People vs. Suarez y Magtagnob

In March 1936, Rafael, Carmen, Francisco Jr., Ramon, Lourdes, Mercedes, Concepcion, Mariano, Jose, Loreto, Manuel, Rizal and Jimmy Dinglasan sold a 1,631 sqm parcel (Lot 398, OCT No. 3389) at Roxas Avenue and Pavia Street, Roxas City, to Lee Liong, a Chinese citizen.
The transfer was entered in the Register of Deeds of Capiz but the records were destroyed during World War II.

In 1948 the Dinglasans sued the heirs of Lee Liong for annulment of sale and recovery, alleging the transaction violated the alien‐land‐ownership prohibition under the 1935 Constitution.
Trial Court and Court of Appeals dismissed the suit; on June 27, 1956, the Supreme Court held the sale void but barred the Dinglasans from recovery under the pari delicto doctrine.

On July 1, 1968, the Dinglasans filed another recovery suit, invoking Philippine Banking Corporation v. Lui She; Lee’s heirs moved to dismiss on res judicata grounds.
Trial Court denied the motion; on April 22, 1977, the Supreme Court ruled the suit barred by res judicata and directed its dismissal.

On September 7, 1993, Elizabeth Manuel-Lee and Pacita Yu Lee (widows of Lee’s sons) petitioned RTC Branch 17, Roxas City for reconstitution of the lost title in the name of deceased Lee Liong, claiming inheritance through extra-judicial settlements.
On June 10, 1994, RTC ordered reconstitution of the lost OCT in Lee Liong’s name based on an approved plan and technical description; Entry of Judgment issued August 18, 1994.

On January 25, 1995, the Solicitor General petitioned the Court of Appeals to annul the RTC judgment, arguing lack of jurisdiction and the constitutional disqualification of Lee Liong as original owner.
On April 30, 1996, the Court of Appeals declared the reconstitution void for want of jurisdiction; motion for reconsideration was denied on February 18, 1997.

Petitioners filed to the Supreme Court on April 3, 1997, contending the Solicitor General was estopped for not objecting at the RTC level, that title had been settled in prior SC rulings, and that they had been in possession and paid taxes for over 60 years.
The Solicitor General maintained the reconstitution was void as it contravened the constitutional ban on alien land ownership.

Whether the RTC had jurisdiction and whether petitioners were proper parties to seek reconstitution of a title originally issued to an alien disqualified under the 1935 Constitution.
Whether a reconstitution order based solely on an approved plan and technical description, without the owner’s duplicate or secondary evidence, is valid.
Whether the sale to Lee Liong is void ab initio and whether vendor and vendee are barred by pari delicto from recovering title.
Whether the State may still assail the alien acquisition despite prescription and whether subsequent transfers to Filipino citizens cure the constitutional defect.