Case Summary (G.R. No. 128195)
Petitioners’ Acquisition and Reconstitution Proceedings
In 1993, Elizabeth Manuel-Lee and Pacita Yu Lee—widows of Lee Liong’s sons—filed for reconstitution of the lost title to Lot 398, alleging wartime destruction of records. They traced title through extra-judicial settlements by Lee Liong’s heirs and their own succession and donation. The RTC, after reviewing the approved plan and technical description, ordered reissuance of the certificate in Lee Liong’s name on June 10, 1994.
Challenge by the Solicitor General and Court of Appeals Ruling
The Solicitor General procured annulment of the RTC order in the Court of Appeals, arguing lack of jurisdiction because petitioners lacked title derivation from a legally qualified owner. On April 30, 1996, the CA declared the reconstitution void. A motion for reconsideration by petitioners was denied on February 18, 1997, prompting the present certiorari petition.
Supreme Court’s Jurisdictional and Standing Analysis
The Supreme Court held that a reconstitution petition must be filed by the person lawfully entitled to the original title. Because Lee Liong, the original grantee, was constitutionally disqualified from owning land, petitioners derived no valid right. The Court recognized that only the Solicitor General may challenge such unconstitutional transfer, and that prescription does not bar State action.
Alien Ownership Prohibition and Doctrine of Pari Delicto
Under Article XII, Section 7 of the 1987 Constitution (and the corresponding 1935 provision for the original sale), aliens may not acquire private agricultural or residential land. Both vendor and alien vendee were equally culpable; courts will not aid either under pari delicto. Consequently, title cannot revert to the alien grantee nor to the original sellers. The State, through the Solicitor General, may pursue escheat or reversion.
Curing of Original Defect through Subsequent Filipino Ownership
The Court noted that the constitutional aim of keeping land in Filipino hands is fulfilled if an initially invalid transfer eventually places title with Filipinos. Lee Liong’s heirs, all Filipino citizens, have possessed the property for decades, paying taxes continuously. Such subsequent qualified ownership cures the original flaw.
Legal Requirements for Titl
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Facts
- In March 1936, Rafael, Carmen, Francisco Jr., Ramon, Lourdes, Mercedes, Concepcion, Mariano, Jose, Loreto, Manuel, Rizal and Jimmy Dinglasan sold Lot 398 (approx. 1,631 sqm), Capiz Cadastre, covered by Original Certificate of Title No. 3389, to Lee Liong, a Chinese citizen.
- Lee Liong died intestate in February 1944. His widow Ang Chia and sons Lee Bun Ting and Lee Bing Hoo executed an extra-judicial settlement (June 30, 1947) adjudicating the same lot to themselves.
- Elizabeth Manuel-Lee acquired a share through extra-judicial settlement and donation from her husband Lee Bing Hoo; Pacita Yu Lee succeeded to her share by extra-judicial settlement from her husband Lee Bun Ting.
- The Register of Deeds records for Roxas City, including the original transfer certificate in Lee Liong’s name issued December 9, 1948, were destroyed during World War II.
Procedural History
- 1948: Original Dinglasan vendors sued Lee Liong’s heirs in CFI Capiz for annulment of sale and recovery, citing alien-ownership prohibition. Trial court and CA dismissed; on June 27, 1956 the Supreme Court affirmed sale void but denied recovery under pari delicto.
- July 1, 1968: The same Dinglasans filed a second recovery suit; heirs of Lee Liong moved to dismiss for res judicata. CFI denied; on April 22, 1977 the Supreme Court annulled orders and dismissed suit for res judicata.
- September 7, 1993: Petitioners Elizabeth Lee and Pacita Lee filed with RTC Roxas City (Branch 17) a petition for reconstitution of the lost Certificate of Title in Lee Liong’s name.
- June 10, 1994: RTC ordered reconstitution of the lost title on basis of approved plan and technical description. Entry of Judgment issued August 18, 1994.
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