G.R. No. 247367, December 05, 2022
Maria Luisa Morales, Petitioner, vs. Abner de Guia, represented by his Attorney-in-Fact, Nomeriano de Guia, Respondent.

FACTS

In 1966, Abner de Guia (Abner), then a Filipino citizen, purchased an unregistered parcel of land from the Spouses Sabangan, evidenced by a Deed of Sale of Miscellaneous Improvements and Transfer of Possessory Rights over Land. In 1968, at the request of former Mayor Amelia Gordon, Abner allowed Dominador Morales and his family (Morales Family) to stay on the property. In 1975, Dominador and Abner’s wife executed an Agreement wherein Dominador acknowledged Abner’s superior right as owner and agreed to act as overseer and tenant, staying rent-free and agreeing to vacate upon notice. Abner and his family later migrated to the USA, where Abner became a naturalized American citizen. Unknown to Abner, the Morales Family secured tax declarations in their names over portions of the property and applied for title. In 2000, Abner, represented by his attorney-in-fact, filed an action for recovery of possession and ownership, annulment of tax declarations, and damages against the Morales Family and others. The Regional Trial Court (RTC) ruled in favor of Abner, ordering the defendants to vacate, cancel the tax declarations, and pay damages. The Court of Appeals (CA) affirmed the RTC decision. Maria Luisa Morales, one of the defendants, filed the present petition.

ISSUE

Whether the CA erred in affirming the RTC decision which ruled in favor of Abner de Guia, an American citizen, in an action for recovery of possession and ownership of an unregistered parcel of land, despite the constitutional prohibition against aliens owning lands of the public domain.

RULING

The Supreme Court DENIED the petition and AFFIRMED the CA decision. The Court held that Abner, having purchased the unregistered land in 1966 while still a Filipino citizen, acquired a vested right of ownership. His subsequent loss of Philippine citizenship did not divest him of this previously acquired property right. The constitutional prohibition against aliens acquiring lands of the public domain does not apply to the acquisition of private lands. The Deed of Sale constituted a contract of sale over a private land, transferring ownership from the Spouses Sabangan to Abner. Furthermore, the Morales Family, as tenants/caretakers under the 1975 Agreement, are estopped from denying Abner’s title pursuant to Article 1436 of the Civil Code. Their act of securing tax declarations in their own names and applying for title constituted bad faith. Thus, Abner validly maintained his action to recover possession and ownership based on the strength of his title.