G.R. No. 108998 August 24, 1994
REPUBLIC OF THE PHILIPPINES, petitioner, vs. THE COURT OF APPEALS AND SPOUSES MARIO B. LAPIÑA AND FLOR DE VEGA, respondents.

FACTS

On June 17, 1978, respondent spouses Mario B. Lapiña and Flor de Vega, who were then natural-born Filipino citizens, purchased Lots 347 and 348 in San Pablo City from Cristeta Dazo Belen. The spouses later became Canadian citizens through naturalization. On February 5, 1987, they filed an application for registration of title over the lots before the Regional Trial Court. The Republic of the Philippines opposed the application. The trial court granted the application, confirming the spouses’ title. The Court of Appeals affirmed the trial court’s decision, reasoning that the prohibition against aliens acquiring private lands did not apply because the spouses were Filipino citizens at the time of purchase, and registration merely confirms existing ownership. The Republic filed a petition for review, arguing that the spouses had not acquired proprietary rights before becoming aliens and that unregistered lands are presumed public under the Regalian doctrine.

ISSUE

Can a foreign national apply for registration of title over a parcel of land which he acquired by purchase while still a citizen of the Philippines, from a vendor who has complied with the requirements for registration under the Public Land Act (CA 141)?

RULING

Yes. The Supreme Court affirmed the decision of the Court of Appeals. The Court held that the constitutional prohibition against aliens acquiring private lands applies only to the time of acquisition. Since the respondent spouses were Filipino citizens when they purchased the land, the prohibition was inapplicable. The Court further ruled that for purposes of confirmation of title under Section 48(b) of the Public Land Act, as amended, the possession of the applicant’s predecessors-in-interest can be tacked to the applicant’s possession. The evidence established that the spouses’ predecessors-in-interest had been in open, continuous, exclusive, and notorious possession of the alienable and disposable land since at least 1937, which is more than the required period since June 12, 1945. Therefore, all conditions for a government grant were conclusively presumed complied with, entitling the spouses to registration. The Court also noted that Batas Pambansa Blg. 185, which imposes limitations on land acquisition by former natural-born citizens, was not applicable as the spouses were transferees while still Philippine citizens.