G.R. No. 85279 - Social Security System Employees Association vs. Court of Appeals

The case involves the acquisition by respondent William H. Quasha, an American citizen, of a parcel of private agricultural land located at 22 Molave Place, Forbes Park, Makati, Rizal, with permanent improvements and an area of approximately 2,616 sq. m., as evidenced by Transfer Certificate of Title No. 36862.
The purchase was made on November 26, 1954, before the effectivity of the later Laurel-Langley Agreement, thus falling under the legal framework applicable at that time.

On March 19, 1968, Quasha filed a petition in the Court of First Instance of Rizal seeking a declaration of his rights under the so-called Parity Amendment to the Philippine Constitution.
Quasha’s petition asserted that although his acquisition was valid, the uncertainty arising from the constitutional limitation—specifically claiming that rights acquired by American citizens under the Amendment would cease on July 3, 1974—reduced the property’s value and hindered further improvements.
He argued that the ownership acquired during the effectivity of the Parity Amendment should continue even after the amendment’s termination, i.e., beyond the stipulated expiration date.

The Solicitor General, whose office was represented first by Antonio P. Barredo and subsequently by Felix V. Makasiar and Felix Q. Antonio, contested the validity of the acquisition on two main grounds:

That the property, being private agricultural land, fell under the prohibition in Section 5, Article XIII of the Constitution, which limits transfer of such lands to non-Filipinos except by hereditary succession.
That, even if the acquisition were deemed valid, the rights conferred by the acquisition would automatically expire at the end of July 3, 1974, when the Parity Amendment’s effect ceases.

The case also involved a detailed analysis of the historical background and constitutional provisions concerning the disposition, exploitation, development, and utilization of both public and private agricultural lands, including references to:

The original constitutional provisions of Article XIII (Sections 1, 2, and 5) and Article XIV (Section 8),
The Philippine Trade Act (Commonwealth Act No. 733),
The Executive Agreement of July 4, 1946, and
The ensuing Parity Amendment ratified in November 1946.

The legal analysis involved elucidating the nationalistic spirit enshrined in the Constitution, limiting foreign (American) involvement in the exploitation of natural resources and ownership of agricultural lands.
The background included references to the devastation during the Japanese occupation, the subsequent need for American assistance, and legislative measures taken (e.g., Public Law 3721, Commonwealth Act No. 733) to open up certain rights to U.S. citizens under strict conditions.
The Parity Amendment specifically provided an exception to the constitutional limitations on the exploitation of public agricultural lands and the operation of public utilities for a fixed period (until July 3, 1974), without modifying the provisions relating to the acquisition or transfer of private agricultural lands.

Whether, under the Parity Amendment to the Constitution, American citizens and business enterprises owned or controlled by them are entitled to acquire and own private agricultural lands in the Philippines (outside of cases of hereditary succession).
Whether the rights, assumed to be valid at the time of acquisition in 1954, continue in full ownership beyond July 3, 1974, or whether they become resolvable (expiring automatically) upon reaching that date.