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Halili V CA

The Supreme Court ruled that the transfer of land from Helen Meyers Guzman to her son David Rey was unconstitutional, as only Filipinos can own land. However, the subsequent sale of the property to Emiliano Cataniag, a Filipino citizen, cured the initial defect, rendering the title valid. The Court emphasized that previous jurisprudence supports the notion that an invalid transfer can be rectified through a subsequent valid transfer to a qualified citizen.

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Kristine Padilla
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33 views1 page

Halili V CA

The Supreme Court ruled that the transfer of land from Helen Meyers Guzman to her son David Rey was unconstitutional, as only Filipinos can own land. However, the subsequent sale of the property to Emiliano Cataniag, a Filipino citizen, cured the initial defect, rendering the title valid. The Court emphasized that previous jurisprudence supports the notion that an invalid transfer can be rectified through a subsequent valid transfer to a qualified citizen.

Uploaded by

Kristine Padilla
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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CELSO and ARTHUR HALILI v. CA GR No.

113539
March 12, 1998
Topic: Validity of sale/ Subsequent valid transfer

FACTS:
Simeon de Guzman, an American Citizen, died and left real properties in
the Philippines to his heirs – his widow Helen Meyers Guzman and his son,
David Rey – both of who are American citizens. Consequently, Helen
executed a quitclaim transferring her rights, titles and interests in six
parcels of land to David Rey, including the disputed parcel in Sta. Maria,
Bulacan. The said transfer was registered and eventually sold by David
Rey to a certain Emiliano Cataniag who is a Filipino citizen.

Petitioners who are owners of a lot adjoining the subject property filed a
complaint before the RTC of Bulacan, challenging the constitutionality of
the land transfer. RTC dismissed the complaint. On appeal to CA,
petitioners sought to declare the conveyance from Helen to David Rey null
and void. CA upheld the RTC’s decision thus this appeal under Rule 45.

ISSUE:
Whether the conveyance from Helen Meyers Guzman to David Rey
Guzman should be declared null and void for being unconstitutional

RULING:
No. The Court held that while the deed of quitclaim executed by Helen
Guzman to her son David Rey Guzman was constitutionally infirm since
only Filipinos are qualified to own land, the subsequent sale of the subject
property to Emiliano Cataniag who is a qualified Filipino citizen cured the
defect.

In ruling such, the Court banked on previous jurisprudence which provides


that "if 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 (also
ruled in Godinez vs. Pak Luen, De Castro vs. Tan).

Notes:
Non-Filipinos are disqualified from owning land in the Philippines, yet
subsequent transfer to a Filipino citizen cures the invalidity.

Article 1621 of the Civil Code applies only to rural lands. Given both
properties’ urban status, petitioners’ invocation of this right was invalid.
The provision’s purpose, aimed at agricultural development, was
irrelevant in this context.

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