made by the trial court clarifying the prohibition made on Krivenko. The court held that “while aliens are disqualified to Acquire lands under the 1935 Constitution, citizens of the United States can acquire lands like Filipino citizens.” Thus, while Krivenko laid down the ruling to prohibit all aliens or those of foreign nationals from acquiring agricultural land in the Philippines, an exception was made in the form of the Ordinance appended to the 1935 Constitution by Resolution No. 39 of the National Assembly dated September 15, 1939, hereinafter provided for: Clearly, while Krivenko laid down the foundation for prohibition on aliens acquiring land in the Philippines, it is not an absolute ruling and admits of exceptions. References Supreme Court of the Philippines cases