RP v.

REGISTER OF DEEDS OF ROXAS CITY

FACTS:

1.In March 1936, Lee Liong, a Chinese citizen, bought Lot No. 398 (1,574 m2)
from Vicenta Arcenas and 7 Dinglasan’s. In Feb. 1944, Lee Liong died intestate and
was survived by his widow Ang Chia and his sons Lee Bing Ho and Lee BunTing. On
June 30, 1947, the surviving heirs of Lee Liong extrajudicially settled the estate of the
deceased and partitioned among themselves Lot No. 398. When the sons died, the lot
was then transferred by succession to their respective wives Elizabeth Lee and Pacita
Yu-Lee.

2. In the case of Dinglasan v. Lee Bun Ting, involving the same lot, the Court
held that even if the sale of the property was null and void for violating the constitutional
prohibition on the sale of land to an alien, still the doctrine of in pari delicto barred the
sellers from recovering title to the property. A subsequent case over the same land was
dismissed applying the doctrine of res judicata.

3.On Sept. 7, 1993, Elizabeth and Pacita filed a petition for reconstitution of title
of Lot No. 398 because the records of the Register of Deeds, Roxas City were burned
during the war. On Oct. 3, 2001, the Court held that the TC’s order of reconstitution was
void for lack of factual support because it was based merely on the plan & technical
description approved by the Land Registration Authority.

4.Meanwhile, on Jan. 26, 1995, the RP filed with the RTC a Complaint for
Reversion of Title, praying that the sale of Lot No. 398 to Lee Liong be set aside for
being null and void ab initio, thus never forming part of the deceased’s estate, and that
the lot be reverted to the public domain for the State’s disposal in accordance with law.
Respondents invoked the following as affirmative defenses: prescription, private
ownership of Lot No. 398, and Lee Liong’s being a buyer in good faith and for value.
Furthermore, respondents claimed that, being Filipino citizens, they are qualified to
acquire Lot No. 398 by succession.

5.TC ordered reversion, ruling that respondents could not acquire title to the land,
the sale to their predecessor-in-interest being null and void. CA reversed, ruling that the
transfer to respondents of the lot cured the flow in the orig transaction.

ISSUE:

WoN reversion proceedings is still viable, considering that the lot

has already been transferred to Filipino citizens—NO.RULING: Petition DENIED.
RATIO:

1.This case is similar to De Castro v. Teng Queen Tan, where the Court
independently of the doctrine of in pari delicto, sustained the sale, holding that while the
vendee was an alien at the time of the sale, the land has since become the property of a
naturalized Filipino citizen.

2.As the Court held in Dinglasan v. Lee Bun Ting, although ownership of the land
cannot revert to the original sellers because of the doctrine of in pari delicto,the OSG
may initiate an action for reversion/escheat of the land to the State. But in this case,
subsequent circumstances militate against escheat proceedings because the land is
now in the Filipinos’ hands. The constitutional proscription on alien ownership of lands
was intended to protect lands from falling in the hands of non-Filipinos. In this case,
however, there would be no more public policy violated since the land is in the hands of
Filipinos qualified to acquire and own such land. 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.

3.In this case, the reversion proceedings was initiated only after 40 years from
Dinglasan v. Lee Bun Ting, and the land has already been transferred by
succession to Filipino citizens. In Chavez v. PEA, the law disregards the
constitutional disqualification of the buyer to hold land if the land is
subsequently transferred to a qualified party, or the buyer himself becomes a qualified
party.