REPUBLIC vs REGISTER OF DEEDS (Special Proceedings)

REPUBLIC OF THE PHILIPPINES, represented by the DIRECTOR OF LANDS,
Petitioner,
- versus -
REGISTER OF DEEDS OF ROXAS CITY, ELIZABETH LEE, and PACITA YU-LEE,
Respondents.
G.R. No. 158230

FACTS:

Lee Liong, a Chinese citizen, bought Lot No. 398 from  Dinglasan siblings. Lee Liong died intestate and was survived by his widow Ang Chia, and his sons Lee Bing Hoo and Lee Bun Ting. The surviving heirs of Lee Liong extrajudicially settled the estate of the deceased and partitioned among themselves Lot No. 398. When Lee Bing Hoo and Lee Bun Ting died, Lot No. 398 was transferred by succession to their respective wives, Elizabeth Lee (Elizabeth) and Pacita Yu-Lee (Pacita) who are Filipino citizens.

ISSUE:

Whether Lot No. 398 can be subject of escheat.

RULING:

No, Court has ruled consistently that where a Filipino citizen sells land to an alien who later sells the land to a Filipino, the invalidity of the first transfer is corrected by the subsequent sale to a citizen. Similarly, where the alien who buys the land subsequently acquires Philippine citizenship, the sale was validated since the purpose of the constitutional ban to limit land ownership to Filipinos has been achieved. In short, 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.

Clearly, since Lot No. 398 has already been transferred to private respondents who are Filipino citizens, the prior invalid sale to Lee Liong can no longer be assailed. Hence, reversion proceedings will no longer prosper since the land is now in the hands of Filipino citizens.