Mercado based on their right to repurchase the property offering to pay for his liabilities which Bio rejected, claiming that the right to repurchase had already expired. Plaintiffs in this case raised the constitutional question because Bio is a Chinese citizen. The court reiterated the ruling as established in Krivenko, stating: The case of Halili v CA once again highlighted the importance of this case, thus stating: “the landmark case of Krivenko vs. Register of Deeds settled the issue as to who are qualified (and disqualified) to own public as well as private lands in the Philippines.” However, the issue at hand involved the subsequent sale from an alien to a qualified Filipino citizen. Jurisprudence is consistent that "if land is invalidly transferred to an alien who subsequently becomes a citizen or transfers it to a citizen, the flaw in the original transaction is considered cured and the title of the transferee is rendered valid." The court thus held that the selling and acquisition of a Filipino citizen of land improperly transferred to a foreign national is thereby cured because the purpose of the lawmakers, as gleaned from the Krivenko ruling, of keeping the land to Filipinos is thereby upheld. It can be seen here that not only the ruling made in Krivenko is considered by subsequent jurisprudence but discussions made therein as well. The Krivenko doctrine has a far reaching application and unless subsequently overruled, remains to be a controlling doctrine in Philippine jurisprudence. Public Impact A little over two months after the promulgation of the decision by the Court on the Krivenko case, the implication of the ruling is made apparent by a subsequent case. The court narrated in Cabauatan et al. v Hoo that: On March 18, 1943, plaintiffs sold to Uy Hoo, married to By Siat, and Siy Hong, a widow, all Chinese citizens tivo parcels of residential land situated in the City of Manila, Philippines, which were formerly described in Transfer Certificate of Title No. 63967, in consideration of the sum of P13,000 in Japanese war notes. In view of said transfer, the Register of Deeds of the City of Manila cancelled Transfer Certificate of Title No. 63967 and issued in lieu thereof Transfer Certificate of Title No. 69938 in the name of the purchasers. On November 15, 1947, the case of Krivenko v. Register of Deeds, G. R. No. L-630 was decided by this