Case Digest (G.R. No. L-3676)
Facts:
Socorro Vasquez v. Li Seng Giap and Li Seng Giap & Sons, G.R. No. L-3676, January 31, 1955, the Supreme Court En Banc, Padilla, J., writing for the Court. Plaintiff-appellant Socorro Vasquez brought an action to annul (styled in the complaint as rescission) a contract of sale by which, on January 22, 1940, she sold a parcel of land in Tondo, City of Manila, with improvements, to defendant Li Seng Giap for P14,500. At the time of that sale Li Seng Giap was a Chinese citizen.By stipulation of facts the parties agreed that on August 21, 1940 Li Seng Giap sold the same parcel to Li Seng Giap & Sons, Inc., and the transfer was registered August 23, 1940. At the time of the corporate acquisition the corporation’s shares were then owned by Chinese citizens; the title was registered in Transfer Certificate of Title No. 59684.
The stipulation further established that Li Seng Giap was naturalized as a Filipino on May 10, 1941 (Certificate of Naturalization No. 515), and that beginning in 1946 the corporate shareholder roll reflected that Filipinos then held 96.67% of the outstanding stock (with Li Seng Giap and several Lee family members as Filipino stockholders). The stipulation detailed the naturalization dates of several individual stockholders and the composition and percentages of stock ownership.
The trial court (recorded simply as “the Court” in the stipulation) rendered judgment dismissing Vasquez’s complaint with costs. Vasquez appealed to the Supreme Court. The central contention below and on appeal was that the original vendee, being an alien at the time of purchase, was constitutionally incapable of owning land and that the sale was th...(Pro-only)
Issues:
- May the vendor annul the sale on the ground that the vendee, at the time of conveyance, was an alien incapable of owning land under the Constitution?
- Does the subsequent naturalization of the original vendee and the later Filipino majority ownership of the transferee corporation validate the title so as to defeat an action to annul the sale?
- Does the rule in pari delicto bar relief to the vendor in a sale to...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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