Halili v.

Court of Appeals
G.R. No. 113539, March 12, 1998

Simeon de Guzman, an American citizen, died sometime in 1968, leaving real properties in the hilippines.
His forced heirs were his widow private respondent Helen Meyers Guzman, and his son, private
respondent David Rey Guzman, both of whom are also American citizens. On August 9,
1989, Helen executed a deed of quitclaim, assigning, transferring and conveying to David Rey all her
rights, titles and interests in and over six parcels of land which the two of them inherited from Simeon.
Among the said parcels of land is that now in litigation Guzman then sold the parcel of land to Catanaig,
who is one of respondents in this case. Petitioners, who are owners of the adjoining lot, filed a complaint
before the Regional Trial Court of Malolos, Bulacan, questioning the constitutionality and validity of the
two conveyances — between Helen Guzman and David Rey Guzman, and between the latter
and Emiliano Cataniag — and claiming ownership thereto based on their right of legal redemption
under Art. 1621 of the Civil Code. The trial court dismissed the complaint. The CA denied the appeal of
the Halilis.

ISSUE: Whether or not the sale of the land is null and void.

No, because the prohibition in the constitution has already been served. Article
XII, Section 7 provides that Non- Filipinos cannot acquire or hold title to private lands or
to lands of the public domain, In fine, non-Filipinos cannot acquire or hold title to private
lands or to lands of the public domain, except only by way of legal succession. While it
is true that the transfer of Helen of his right to her son who is an American citizen
contradicts the prohibition set forth in the Constitution, the Supreme Court upheld the
subsequent sale of the land to Catanig, a Filipino citizen. Jurisprudence is consistent
that “if land is invalidly transferred to an alien who subsequently becomes a citizen or
transfers it to a citizen, the flaw in the original transaction is considered cured and the
title of the transferee is rendered valid.”
The rationale of this principle was explained in Vasquez vs. Li Seng Giap thus
“[I]f the ban on aliens from acquiring not only agricultural but also urban lands, as
construed by this Court in the Krivenko case, is to preserve the nation’s lands for future
generations of Filipinos, that aim or purpose would not be thwarted but achieved by
making lawful the acquisition of real estate by aliens who became Filipino citizens by
naturalization. “
Petition was denied.

Halili v. CA
May 24, 2018
Civil Law. Sales. Transfer of interest (piece of land) to an alien.
Celso R. Halili & Arthur R. Halili v. CA, Helen Meyers Guzman, David Rey Guzman and Emiliano
Cataniag
G.R. No. 113539, March 12, 1998
Panaganiban, J..:
FACTS:

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Petitioners appealed from the decision of the MTC and RTC ruling that Helen Guzman’s (American
citizen) waiver of her inheritance in favor of her son was not contrary to the constitutional prohibition
against the sale of land to an alien.
Simeon de Guzman, an American citizen, died sometime in 1968, leaving real properties in the
Philippines. His forced heirs were his widow, defendant-appellee Helen Meyers Guzman, and his son,
defendant-appellee David Rey Guzman, both of whom are also American citizens. Helen executed a deed
of quitclaim assigning, transferring and conveying to David Rey all her rights, titles and interests in and
over six parcels of land which the two of them inherited from Simeon. Subsequently, David Rey Guzman
sold said parcel of land to defendant-appellee Emiliano Cataniag.
Petitioners, who are owners of the adjoining lot, filed a complaint questioning the constitutionality and
validity of the two conveyances and claiming ownership thereto based on their right of legal redemption
under Art. 1621[5] of the Civil Code.
ISSUES:
Were the petitioners entitled to a right of redemption?
Was the sale of the lot to defendant-appellee Cataniag valid?
HELD:
NO. The petitioners were not entitled to a right of redemption. The subject land is urban. Thus, petitioners
have no right to invoke Art. 1621 of the Civil Code, which presupposes that the land sought to be
redeemed is rural.
YES. The sale to Cataniag is valid. Non-Filipinos cannot acquire or hold title to private lands or to lands
of the public domain. But what is the effect of a subsequent sale by the disqualified alien vendee to a
qualified Filipino citizen? Jurisprudence is consistent that if the land is invalidly transferred to an alien
who subsequently becomes a citizen or transfers it to a citizen, the flaw in the original transaction is
considered cured and the title of the transferee is rendered valid. Since the disputed land is now owned by
Private Respondent Cataniag, a Filipino citizen, the prior invalid transfer can no longer be assailed. The
objective of the constitutional provision — to keep our land in Filipino hands — has been served.

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