Beumer vs. Amores

A foreign national who knowingly purchases private land in the Philippines in violation of the Constitution cannot seek reimbursement for the funds used in the purchase upon the dissolution of the marriage, as equity will not aid a party who comes to court with unclean hands and the law will leave the parties to an illegal transaction where it finds them.

The dispute arose following the nullification of the marriage between a Dutch husband and a Filipina wife. The husband subsequently filed for the dissolution of their conjugal partnership, claiming rights to, or reimbursement for, real properties acquired during the marriage which were registered in the wife's name due to the constitutional prohibition against alien land ownership.

• Petitioner Willem Beumer, a Dutch national, and respondent Avelina Amores, a Filipina, were married on March 29, 1980.
• The Regional Trial Court (RTC) declared the nullity of their marriage on November 10, 2000, based on Willem's psychological incapacity.
• Willem filed a Petition for Dissolution of Conjugal Partnership, claiming that four specific lots were acquired by purchase during the marriage using his disability benefits from the Dutch government.
• During trial, Willem admitted he was well aware of the constitutional prohibition against foreigners owning land in the Philippines and that the properties were registered in Avelina's name to circumvent this law.
• Avelina contended that she purchased the lots using her own personal funds derived from selling jewelry and other products, and that Willem only contributed to the purchase of tools and equipment.
• The RTC ruled that the lots were Avelina's paraphernal property because Willem, as a foreigner, was disqualified from acquiring private land, though it declared the houses on the lots as co-owned and the tools as Willem's exclusive property.
• The RTC denied Willem's claim for reimbursement on the basis of equity because he did not come to court with clean hands.

• The money used to purchase the subject properties came from his own capital funds (disability benefits).
• The properties were registered in the respondent's name solely because of the constitutional prohibition against foreign ownership.
• He is entitled to reimbursement of one-half of the purchase price based on equity and the principle against unjust enrichment, waiving the other half in favor of the respondent.

• She and the petitioner did not acquire any conjugal properties during their marriage except for the two residential houses.
• She used her own personal money to purchase the subject lots from her earnings selling jewelry, Avon, Triumph, and Tupperware products.
• The petitioner had previously executed a joint affidavit attesting that she purchased one of the lots and the improvements thereon using her own money.

• Procedural Issues:
  • N/A
• Substantive Issues:
  • Whether a foreign national may claim reimbursement for the purchase price of Philippine lands acquired during the marriage but registered in the name of his Filipina spouse due to the constitutional prohibition against alien land ownership.

• Procedural:
  • N/A
• Substantive:
  • The Court denied the petition and affirmed the CA's decision, ruling that the petitioner is not entitled to reimbursement for the funds used to purchase the land.
  • The Court applied the ruling in Muller v. Muller, stating that a foreigner who willingly and knowingly buys property despite the constitutional prohibition cannot seek reimbursement on the ground of equity.
  • The Court held that the petitioner came to court with "unclean hands" by admitting he attempted to skirt the constitutional prohibition; thus, he cannot seek equitable relief.
  • The Court ruled that the principle of unjust enrichment (Article 22 of the Civil Code) does not apply when the action is proscribed by the Constitution or barred by the pari delicto doctrine.
  • The Court emphasized that a contract violating the Constitution is null and void, and the law leaves the parties where it finds them, vesting no rights and creating no obligations.

• In Pari Delicto — A legal principle stating that when two parties are equally at fault or involved in an illegal act, the court will not aid either party and will leave them where they are; applied here to bar the petitioner from recovering money spent on an illegal transaction (foreign land ownership).
• Clean Hands Doctrine — An equitable maxim requiring that a party seeking equitable relief must not have acted unethically or illegally regarding the subject of the claim; used to deny the petitioner's claim because he knowingly circumvented the Constitution.
• Unjust Enrichment (Accion in rem verso) — The principle under Article 22 of the Civil Code that no person should unjustly enrich themselves at the expense of another; the Court ruled this does not apply when the transaction is constitutionally prohibited or illegal.
• Constitutional Prohibition on Alien Land Ownership — Based on Section 7, Article XII of the 1987 Constitution, prohibiting the transfer of private lands to individuals not qualified to acquire public lands (i.e., foreigners); used as the primary basis to declare the petitioner's purchase attempts void.

• "He who seeks equity must do equity, and he who comes into equity must come with clean hands."
• "Surely, a contract that violates the Constitution and the law is null and void, vests no rights, creates no obligations and produces no legal effect at all."
• "The law will not aid either party to an illegal contract or agreement; it leaves the parties where it finds them."
• "Needless to state, the purpose of the prohibition is to conserve the national patrimony and it is this policy which the Court is duty-bound to protect."

• In Re: Petition For Separation of Property Elena Buenaventura Muller v. Helmut Muller — Cited as controlling precedent where the Court denied a similar claim for reimbursement by a foreigner who knowingly bought Philippine land.
• Frenzel v. Catito — Cited to support the ruling that unjust enrichment does not apply if the action is proscribed by the Constitution.
• Cheesman v. Intermediate Appellate Court — Cited regarding the constitutional prohibition against foreign ownership.
• Rellosa v. Hun — Cited regarding the principle that when both parties are at fault in an illegal contract, neither may recover.
• Krivenko v. Register of Deeds — Cited regarding the purpose of the constitutional prohibition to conserve national patrimony.

• 1987 Constitution, Article XII, Section 7 — Prohibits the transfer or conveyance of private lands to individuals not qualified to acquire lands of the public domain (foreigners).
• Civil Code, Article 22 — Defines unjust enrichment; cited by the petitioner to claim reimbursement but deemed inapplicable by the Court due to the illegality of the transaction.
• Civil Code, Article 1412 — Rules regarding void contracts where the cause is unlawful but not criminal; prevents the petitioner from recovering money spent on the illegal purchase.
• Family Code, Article 36 — The basis for the declaration of nullity of the marriage (psychological incapacity).