### Facts:
On April 12, 1939, Maximino Rico, acting for himself and minors Maria Rico, Filomeno Rico, Prisco Rico, and Lourdes Rico, sold Lot 339 and a portion of Lot 327 in Guinobatan, Albay, to Donato Reyes Yap, a Chinese national at that time. Yap then registered the sale, leading to the issuance of Transfer Certificate of Title No. T-2433 in his favor for both lots.
Nearly fifteen years after this sale, Yap became a naturalized Filipino citizen, and after acquiring citizenship, he transferred a major portion of Lot No. 327 to his engineer son, Felix Yap, also a Filipino citizen. Lourdes Rico later sold the remaining portion of Lot 327 to Yap, who registered this transaction under Act 496. Yap had been in possession of these lots since 1939 until the time of dispute.
Jose A. Rico, claiming inheritance rights, challenged the validity of the sale citing the 1935 Constitution’s provision that prohibited private agricultural land transfer to individuals not qualified to hold land in the Philippines. This case went to the Court of First Instance of Albay, leading to a decision adverse to Yap, which declared the original sale null and void, ordering the reconveyance of the property to Rico.
### Issues:
1. Whether the sale of private agricultural land to a non-Filipino citizen is nullified by the subsequent naturalization of the vendee.
2. If public policy is served by allowing the reconveyance of the property to the original owner despite the vendee’s later naturalization.
### Court’s Decision:
The Supreme Court reversed the decision of the lower court, finding that the subsequent naturalization of Donato Reyes Yap rectified the initial ineligibility to own land in the Philippines. The Court emphasized its previous rulings stating that once the previously ineligible owner becomes a naturalized Filipino citizen, the aim of conserving land for Filipinos is met, and thus, the public policy underlying the constitutional prohibition is satisfied.
The Court made clear that the transition of the property into the hands of a now qualified individual (a naturalized Filipino citizen) removes any further public interest in dispossessing the naturalized citizen of the land. Therefore, the original sale, although initially null and void due to the constitutional prohibition at the time, was effectively ratified by Yap’s naturalization, making the subsequent challenge to the land’s ownership unfounded.
### Doctrine:
The Supreme Court reiterated the doctrine that the subsequent naturalization of an alien who has acquired land in the Philippines validates the previously void transaction. This aligns with the public policy objective of preserving Philippine lands for Filipinos, as naturalization renders the previously ineligible vendee now fully qualified to own land in the Philippines.
### Class Notes:
Key Elements or Concepts:
1. **Constitutional Prohibition of Land Ownership by Non-Filipinos**: The 1935 Constitution explicitly barred non-Filipinos from acquiring agricultural land.
2. **Effect of Naturalization on Land Ownership**: Naturalization of a non-Filipino landowner rectifies the initial constitutional ineligibility to own land in the Philippines.
3. **Public Policy Consideration**: The overarching public policy is the conservation of Philippine lands for Filipinos, which is deemed satisfied once the vendee becomes a Filipino citizen through naturalization.
### Historical Background:
This case underscores the implications of the 1935 Philippine Constitution’s land ownership restrictions on non-Filipinos, reflecting the national policy to keep Philippine lands in Filipino hands. The evolution of this case, leading to the Supreme Court’s decision, also illustrates the judicial perspective on how the naturalization process interacts with constitutional limitations on land ownership, adapting previous judicial doctrines to contemporary realities of citizenship and property rights.
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