- Petitioner
- Alfred Fritz Frenzel
- Respondent
- Ederlina P. Catito
- Citation
- G.R. No. 143958
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Callejo, Sr., J.
- Decided
- July 11, 2003
Summary
Australian citizen Alfred Frenzel financed the purchase of three parcels of land in Davao worth over P700,000 during his relationship with Filipino citizen Ederlina Catito from 1983-1985. Knowing constitutional restrictions on alien land ownership, he had the properties titled in Catito's name. When their relationship ended and marriage plans failed, Frenzel sued to recover the properties or money spent. The Supreme Court dismissed his petition, ruling the transactions violated the 1973 Constitution and were null and void ab initio. Applying the pari delicto doctrine, the Court held that Frenzel, being equally guilty in the illegal transaction, cannot recover from Catito. The decision reinforced constitutional prohibitions against alien land ownership and the principle that courts will not aid parties to illegal contracts.