G.R. No. 206404 - Gaw vs. Chua

Case Summary (G.R. No. 206404)

Petitioner

Concepcion Chua Gaw, claiming an undivided hereditary share in three parcels (Lot Nos. 5370-A, 5662, and 5663) on grounds that her parents used Lu Pieng as a nominee trustee pending their acquisition of Philippine citizenship.

Respondents

Suy Ben Chua, who holds titles over all three lots, and his spouse Felisa Chua. Ben acquired Lot No. 5370-A by donation and Lots Nos. 5662 and 5663 by purchase from their sister Juanita in 1988–1989.

Key Dates

November 22, 1969: Deed of absolute sale by the Santos vendors to Lu Pieng for all three lots.
November 26, 1976 and July 18, 1980: Subsequent sales through Lu Pieng and Lucio to Juanita.
July 28, 1988 and September 20, 1989: Juanita’s donation of Lot No. 5370-A and sale of Lots 5662 and 5663 to Ben.
June 16, 1995 and October 25, 1996: Filing of land registration application by Ben and reconveyance complaint by Concepcion.
April 28, 2008: RTC decision denying Ben’s registration and granting Concepcion’s reconveyance.
August 17, 2012: CA decision affirming denial of registration but dismissing reconveyance.
February 14, 2022: Supreme Court decision affirming the CA.

Properties Involved

· Lot No. 5370-A (2,319 m²), unregistered before Ben’s application.
· Lot No. 5662 (61 m²) and Lot No. 5663 (379 m²), originally registered under Juanita, later transferred to Ben.

Applicable Law

1987 Philippine Constitution, Article XII, Section 7 (foreign ownership ban outside hereditary succession).
Commonwealth Act No. 141 (Public Land Act).
Civil Code Article 1448 (implied or purchase-money resulting trust).

Antecedents of Conveyance

The Santos family sold the three parcels to Lu Pieng, who leased them to Chua Chin and Chan Chi. Testimony later suggested that Chua Chin was the true buyer, with Lu Pieng serving merely as trustee pending the parents’ naturalization. Lu Pieng’s subsequent sale to Lucio, and Lucio’s sale to Juanita, were duly notarized and later transferred to Ben.

Procedural Posture

Ben sought registration of title over Lot No. 5370-A under Land Registration Case No. 25-M-95. Concepcion filed a reconveyance suit in Civil Case No. 804-M-96 for Lots 5662 and 5663, asserting trust obligations. The RTC consolidated both cases.

Trial Court Ruling

The RTC found no continuous adverse possession by Ben’s predecessors, recognized Chua Chin as the true purchaser, and concluded that legal and equitable titles rested with the heirs. It denied Ben’s registration application and granted Concepcion her undivided share in all three parcels.

Court of Appeals Ruling

The CA affirmed the denial of Ben’s registration application but dismissed Concepcion’s reconveyance claim. It upheld the notarized deeds’ regularity and rejected the implied-trust theory as an unlawful circumvention of the constitutional ban on alien land ownership.

Issue

Whether an implied trust resulted in favor of Chua Chin’s heirs over the three subject parcels, despite their parents’ alien status at the time of the initial conveyance.

Supreme Court Ruling – Constitutional Prohibition

Invoking the 1987 Constitution’s explicit ban on foreign acquisition of private lands except by hereditary succession,