Krivenko vs Register of Deeds, GR No. L-630,November 15, 1947; 79 Phil 461(Land Titles and DeedsAliens disqualified fromacquiring public and private lands)Facts:

An alien bought a residential lot and its registration was denied by the Register of Deeds on the ground that being an alien, he cannot acquire land in this jurisdiction. When the former brought the case to the CFI, the court rendered judgement sustaining the refusal of the Register of Deeds.

Issue:

WON an alien may own private lands in the Philippines.

Held:

No. Public agricultural lands mentioned in Sec. 1, Art. XIII of the 1935 Constitution, include residential, commercial and industrial lands, the Court stated:Natural resources, with the exception of public agricultural land, shall not be alienated, and withrespect to public agricultural lands, their alienation is limited to Filipino citizens. But this constitutional purpose conserving agricultural resources in the hands of Filipino citizens may easily be defeated by the Filipino citizens themselves who may alienate theiragricultural lands in favor of aliens. Thus Section 5, Article XIII provides: Save incases ofhereditarysuccession, noprivate agricultural lands will be transferred or assigned except to individuals, corporations or associations qualified to acquire or hold lands of the public domain in the Philippines