El Banco Nacional Filipino, Demandante-Apelante, Contra Ah Sing, Demandado-Apelante

Summary

El Banco Nacional Filipino sought nullification of a 1934 land contract with Chinese citizen Ah Sing, arguing it was merely a promise to sell that became impossible to fulfill due to the 1935 Constitution's prohibition on foreign agricultural land ownership. The Supreme Court reversed the lower court, ruling the contract constituted an absolute sale under Civil Code provisions, not a mere promise. The Court held that the constitutional prohibition could not be applied retroactively to deprive previously acquired property rights, as this would violate due process guarantees. The decision established important precedents on contract interpretation, non-retroactivity of constitutional provisions, and protection of vested property rights against subsequent legislative restrictions.