“…the ban on aliens is intended to preserve the nation’s land for future generations of Filipinos, that aim is achieved by making lawful the acquisition of real estate by aliens who became Filipino citizens by naturalization or those transfers made by aliens to Filipino citizens.“
Wilhelm, an Austrian, fell in love with Antonietta, her Filipina English tutor. They eventually bought a house and lots, in which both of them were designated as buyers.
When they presented the sale documents to the Registry of Deeds (“RD”), however, the RD refused to register the sale because Wilhelm was an alien and could not acquire land, and so they decided to just erase Wilhelm’s name from the sale document.
The couple eventually broke up and found themselves with new partners.
Later, Wilhelm assigned his rights and interests in the house and lots to Camilo to settle his debts to the latter. When Camilo sought to register the assignment, however, he found out that the title to the lots is only in the name of Antonietta, and one of them was even mortgaged.
Camilo sought to recover the property from Antonietta who denied that it was Wilhelm alone who bought the properties. Antonietta argued that she paid for the properties and that Wilhelm could not have brought the properties because he was a foreigner.
The trial court found that it was indeed Wilhelm who bought the properties and that the only reason why they were in the names of Antonietta was because she took advantage of Wilhelm’s goodness.
On appeal, however, the Court of Appeals reversed the trial court’s ruling saying that Wilhelm could not have transferred properties not registered to his name.
The Supreme Court sustained the factual findings of the trial court that Wilhelm was the one who purchased the lots and went on to discuss the effect of the registration of the properties in the name of Antonietta.
“It is settled,” says the Supreme Court, “that registration is not a mode of acquiring ownership. It is only a means of confirming the fact if its existence with notice to the world at large. Certificates of title are not a source of right.”
Following its previous ruling in United Church Board for World Ministries v. Sebastian, the Court reiterated that “if land is invalidly transferred to an alien who subsequently becomes a Filipino citizen or transfers it to a Filipino, the flaw in the original transaction is considered cured and the title to the transferee is rendered valid.”
The Supreme Court affirmed the trial court’s decision to uphold the sale by Wilhelm to Camilo and order the cancellation of the certificates of title in the name of Antonietta.