G.R. No. 128195 ; October 3, 2001
ELIZABETH LEE and PACITA YU LEE, et al., petitioners, vs. REPUBLIC OF THE PHILIPPINES, et al., respondents.

FACTS

In 1936, the Dinglasan siblings sold Lot No. 398 in Roxas City to Lee Liong, a Chinese citizen. In 1948, the vendors sued to annul the sale, arguing its nullity under the constitutional prohibition against alien ownership of private land. The Supreme Court, in Dinglasan v. Lee Bun Ting (1956), denied recovery, applying the principle of pari delicto, barring the equally guilty vendors. In 1968, the same vendors filed another recovery suit. The Supreme Court, in Lee Bun Ting v. Aligaen (1977), dismissed it on the ground of res judicata.
In 1993, petitioners Elizabeth Lee and Pacita Yu Lee, heirs of Lee Liong, filed a petition for reconstitution of the lost Original Certificate of Title (OCT) covering the lot. The Regional Trial Court (RTC) granted the petition in 1994. The Republic, through the Solicitor General, subsequently filed a petition for annulment of judgment with the Court of Appeals (CA), contending the RTC lacked jurisdiction as Lee Liong, an alien, could not acquire valid title.

ISSUE

Whether the Court of Appeals correctly annulled the RTC’s decision ordering the reconstitution of title in the name of Lee Liong.

RULING

Yes, the Court of Appeals correctly annulled the reconstitution judgment. The core legal logic rests on the fundamental principle that jurisdiction over the subject matter is conferred by law and cannot be waived or conferred by the parties. A petition for reconstitution of title presupposes the existence of a valid title that was previously issued. The prohibition under the 1935 Constitution against aliens acquiring ownership of private agricultural land—which includes residential, commercial, and industrial land—is absolute. Consequently, the original sale to Lee Liong was void ab initio. He acquired no valid title that could be reconstituted.
The prior Supreme Court rulings in favor of Lee Liong’s heirs did not validate his title. The 1956 Dinglasan case merely prevented the vendors from recovering the land due to pari delicto; it did not adjudge Lee Liong as the rightful owner. The 1977 Lee Bun Ting case merely barred a second suit on the ground of res judicata. Neither decision cured the inherent nullity of the sale or vested title in the alien vendee. Since no valid title ever existed, the RTC had no jurisdiction to order its reconstitution. The Solicitor General’s failure to object in the RTC did not estop the Republic from challenging a void judgment, as jurisdiction cannot be acquired by consent or acquiescence. The land, therefore, remains part of the public domain.