Thomas C. Cheesman v. Intermediate Appellate Court

Summary

American citizen Thomas Cheesman sued to annul his Filipino wife Criselda's sale of residential property to Estelita Padilla, claiming lack of consent and conjugal nature of property. The Supreme Court affirmed lower courts' findings that the property was Criselda's paraphernal property purchased with her pre-marital funds, and that Estelita was a good faith purchaser. The Court emphasized that the 1973 Constitution prohibits aliens from owning residential land except through hereditary succession. Thomas, being an American citizen, was constitutionally disqualified from claiming any interest in the property. The Court held that allowing Thomas to question the sale would permit indirect controversion of the constitutional prohibition. Both trial and appellate courts found adequate evidence of fraud, mistake or excusable negligence justifying relief to Estelita, and that Thomas's conduct had led Estelita to believe the property belonged exclusively to Criselda. The decision reinforced constitutional restrictions on alien land ownership while protecting innocent purchasers for value.