Civil Law,  Legally Yours

Halili v. Court of Appeals

Civil Law. Sales. Transfer of interest (piece of land) to an alien. 
Celso R. Halili & Arthur R. Halili v. CA, Helen Meyers Guzman, David Rey Guzman and Emiliano Cataniag
G.R. No. 113539, March 12, 1998
Panaganiban, J..:FACTS:
Petitioners appealed from the decision of the MTC and RTC ruling that Helen Guzman’s (American citizen) waiver of her inheritance in favor of her son was not contrary to the constitutional prohibition against the sale of land to an alien.

Simeon de Guzman, an American citizen, died sometime in 1968, leaving real properties in the Philippines. His forced heirs were his widow, defendant-appellee Helen Meyers Guzman, and his son, defendant-appellee David Rey Guzman, both of whom are also American citizens. Helen executed a deed of quitclaim assigning, transferring and conveying to David Rey all her rights, titles and interests in and over six parcels of land which the two of them inherited from Simeon. Subsequently, David Rey Guzman sold said parcel of land to defendant-appellee Emiliano Cataniag.

Petitioners, who are owners of the adjoining lot, filed a complaint questioning the constitutionality and validity of the two conveyances and claiming ownership thereto based on their right of legal redemption under Art. 1621[5] of the Civil Code.


  1. Were the petitioners entitled to a right of redemption?
  2. Was the sale of the lot to defendant-appellee Cataniag valid?


  1. NO. The petitioners were not entitled to a right of redemption. The subject land is urban. Thus, petitioners have no right to invoke Art. 1621 of the Civil Code, which presupposes that the land sought to be redeemed is rural.
  2. YES. The sale to Cataniag is valid. Non-Filipinos cannot acquire or hold title to private lands or to lands of the public domain. But what is the effect of a subsequent sale by the disqualified alien vendee to a qualified Filipino citizen? Jurisprudence is consistent that if the land is invalidly transferred to an alien who subsequently becomes a citizen or transfers it to a citizen, the flaw in the original transaction is considered cured and the title of the transferee is rendered valid. Since the disputed land is now owned by Private Respondent Cataniag, a Filipino citizen, the prior invalid transfer can no longer be assailed. The objective of the constitutional provision — to keep our land in Filipino hands — has been served.

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