Facts: The case revolves around a dispute over real properties acquired by Wilhelm Jambrich, an Austrian national, and his Filipina girlfriend, Antonietta Descallar. After their relationship ended, Jambrich sold his rights in the properties to Camilo F. Borromeo. The trial court ruled in favor of Borromeo, but the Court of Appeals reversed this decision, stating that Jambrich could not transfer properties he did not hold title to, as the titles were in Descallar’s name.
Issue: The primary issue was whether Jambrich, as an alien, could validly transfer his rights to the properties to Borromeo, a Filipino citizen, given that the properties were registered in Descallar’s name.
Ruling: The Supreme Court ruled in favor of Borromeo, stating that since the properties were ultimately in the hands of a qualified person (Borromeo), the public policy aimed at preserving land for Filipinos was satisfied. The Court emphasized that registration is not a mode of acquiring ownership but merely a means of confirming ownership. The Court also noted that the original acquisition by Jambrich, although void ab initio due to his status as an alien, was cured by the subsequent transfer to Borromeo.
Doctrines:
- Indefeasibility of Title: The mere possession of a title does not confer ownership; it is only a means of confirming the existence of ownership.
- Public Policy on Land Ownership: The constitutional prohibition against aliens acquiring land is aimed at preserving land for future generations of Filipinos. This policy is satisfied when land is transferred to a Filipino citizen.
- Co-ownership and Contribution: In relationships where one party is legally married to another, the presumption of co-ownership does not apply unless both parties can prove their contributions to the acquisition of the property.
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