G.R. No. L-31606. March 28, 1983.
Donato Reyes Yap and Melitona Maravillas, petitioners, vs. Hon. Ezekiel S. Grageda, as Judge of the Court of First Instance of Albay and Jose A. Rico, respondents.

FACTS

On April 12, 1939, Maximino Rico and his minor children sold a residential lot in Guinobatan, Albay, to Donato Reyes Yap, who was then a Chinese national. Yap registered the sale, secured a transfer certificate of title, and took possession of the property openly and continuously. Nearly fifteen years later, on June 30, 1954, Yap was naturalized as a Filipino citizen. Subsequently, in 1967, he ceded a portion of the land to his son, a Filipino citizen, and later purchased another portion from a co-heir of the original vendors. In 1968, respondent Jose A. Rico, an heir of the vendors, filed an action for reconveyance, arguing the sale was void under the 1935 Constitution, which prohibited aliens from acquiring private agricultural lands.
The respondent Court of First Instance declared the 1939 sale absolutely null and void ab initio, ordering reconveyance of the property to the vendors’ heir upon repayment of the purchase price. The court ruled that the constitutional prohibition was absolute and that the subsequent naturalization of the vendee did not cure the initial invalidity of the transaction.

ISSUE

Whether the subsequent naturalization of the alien vendee validates a sale of private agricultural land that was void at its inception due to constitutional disqualification.

RULING

The Supreme Court reversed the amended decision and dismissed the complaint. The legal logic is anchored on the primary purpose of the constitutional prohibition. The 1935 Constitution, Section 5, Article XIII, prohibited the transfer of private agricultural lands to individuals not qualified to hold lands of the public domain, a rule designed to preserve the nation’s lands for Filipinos. While a sale to a disqualified alien is indeed void from the beginning, the rationale of the prohibition is not served by allowing recovery when the property has already passed into the hands of a constitutionally qualified person.
The Court applied by analogy its rulings in Vasquez v. Giap and Sarosa Vda. de Bersabia v. Cuenco. In Sarosa, it held that although the original sale to an alien was void, the litigated property was already owned by a naturalized citizen. There was no more public policy to be served in allowing the vendor to recover, as the land was in the hands of a qualified Filipino. The same principle applies here. Donato Reyes Yap had been a naturalized Filipino citizen for fifteen years by the time the suit was filed. The constitutional objective of conserving land for Filipinos is fulfilled, not thwarted, when the alien transferee subsequently becomes a Filipino citizen. Therefore, the initial nullity is cured by the subsequent naturalization, and the vendor or his heirs cannot recover the property.