G.R. No. 113539 March 12, 1998
CELSO R. HALILI and ARTHUR R. HALILI, petitioners, vs. COURT OF APPEALS, HELEN MEYERS GUZMAN, DAVID REY GUZMAN and EMILIANO CATANIAG, respondents.

FACTS

Simeon de Guzman, an American citizen, died in 1968, leaving real properties in the Philippines. His heirs were his widow, Helen Meyers Guzman, and his son, David Rey Guzman, both American citizens. On August 9, 1989, Helen executed a deed of quitclaim assigning her rights, titles, and interests in six parcels of land, including the subject land in Bagbaguin, Sta. Maria, Bulacan, to David Rey. The quitclaim was registered, and TCT No. T-170514 was cancelled and replaced by TCT No. T-120259 in David Rey’s name. On February 5, 1991, David Rey sold the land to Emiliano Cataniag, upon which TCT No. T-120259 was cancelled and TCT No. T-130721(M) was issued in Cataniag’s name. Petitioners Celso R. Halili and Arthur R. Halili, owners of the adjoining lot, filed a complaint questioning the constitutionality and validity of the two conveyances and claiming ownership based on a right of legal redemption under Article 1621 of the Civil Code. The Regional Trial Court dismissed the complaint, ruling that Helen’s waiver was not contrary to the constitutional prohibition and that the land was urban, thus negating the right of redemption. The Court of Appeals affirmed the trial court’s decision.

ISSUE

1. Whether the Court of Appeals erred in affirming the trial court’s conclusion that the land in question is urban, not rural.
2. Whether the Court of Appeals erred in denying petitioners’ right of redemption under Article 1621 of the Civil Code.
3. Whether the Court of Appeals, having considered the conveyance from Helen Meyers Guzman to David Rey Guzman illegal, erred in not declaring the same null and void.

RULING

The Supreme Court DENIED the petition and AFFIRMED the challenged Decision of the Court of Appeals.
1. On the first issue, the Court held that the determination of whether the land is rural or urban is a factual question. The factual findings of the trial court, affirmed by the Court of Appeals, are binding and generally not reviewable. The trial court’s conclusion, based on evidence showing the area was lined with residential, commercial, and industrial establishments, was that the land was urban. The case did not fall within any exception to the rule on factual review.
2. On the second issue, the Court held that since the subject land was urban, petitioners had no right to invoke Article 1621 of the Civil Code, which applies only to rural land not exceeding one hectare. The purpose of the provision is to favor agricultural development, which would not be served if applied to urban land.
3. On the third issue, the Court held that while the transfer from Helen Guzman to David Rey Guzman may have been invalid under the constitutional prohibition (Article XII, Section 7) against aliens acquiring private lands, the subsequent sale of the land to Emiliano Cataniag, a Filipino citizen, rendered the prior invalid transfer no longer assailable. The constitutional objective to keep land in Filipino hands had been achieved. Citing precedents like Tejido vs. Zamacoma and Yap vs. Grageda, the Court ruled that the sale to a qualified citizen cured the constitutional defect.