Lee v. Director of Lands
G.R. No. 128195
October 3, 2001
Facts:
· March 1936
o Rafael, Carmen, et al., all surnamed Dinglasan, sold to Chinese citizen Lee Liong a parcel of land situated at Roxas City.
· 1948
o the former owners filed an annulment of sale and recovery of land
o Reason: The Constitution prohibits against aliens owning private lands
o Ruling of Supreme Court: Sale is null and void but the original owners can’t have the title because they also violated the Constitution. They are in pari delicto.
· 1993
o Filipino citizens Elizabeth Manuel-Lee and Pacita Yu-Lee, who are the widows of the sons of Lee Liong, filed a petition for reconstitution. Both Elizabeth and Pacita acquired the land from their husbands.
o They alleged that on December 9, 1948, a certification of a transfer title over the property was issued in the name of Lee Liong but was burned during the war. However, Elizabeth and Pacita did not show an evidence of owner’s duplicate copy.
o Ruling of the RTC: Order of reconstitution is granted.
· 1995
o Solicitor General filed for a petition of judgment in the reconstitution case
o Reason: RTC Roxas had no jurisdiction over the case
o Contention: Petitioners are not the proper party because Lee Liong did not acquire the title of the land because he is Chinese
o Ruling of the CA: Reconstitution judgment is void.
Issues:
1. Who was the proper party to assail the legality of the sale?
2. Was the Solicitor General estopped because he filed the case 60 years after?
3. Can the Solicitor General escheat the estate now that the land is owned by Filipinos?
4. Was the reconstitution valid?
Ruling:
1. The Solicitor General is the proper party to assail the legality of the sale. Both vendor and vendee are in pari delicto for violating the Constitution, and the courts will not afford protection to either party.
2. No. The SolGen is not estopped because prescription never lies against the State.
3. No. The land is now in the hands of Filipinos. If the land was 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 valid.
4. No. The petitioners failed to present the owner’s duplicate of the title. The order of restitution is void for lack of factual support.
It's a Ping Thing 