Rosa Silagan v. Intermediate Appellate Court

Summary

Rosa Silagan sought to enforce property agreements for Lots 630-A and 630-C, claiming prior purchase from Rita Macabasag through private documents in 1958. However, Macabasag subsequently sold the same lots to Tito K. Yao and Chun Peng through registered public instruments, who later sold to Daniel Cabigon and Chan Yan Peng. Silagan alleged the public sales were simulated trusts to secure loans from the Wei Due Association. The Supreme Court affirmed dismissal of her action, ruling that enforcement would violate the Constitution since the property was intended for her Chinese national common-law husband. Applying the 'clean hands' doctrine and pari delicto principle, the Court held that no relief could be granted for agreements designed to circumvent constitutional prohibitions on alien land ownership. The Court also found the evidence regarding Silagan's adverse claim annotation questionable, with signs of post-facto tampering.