Act 141, among others. The general tenor of those references is that agricultural land does not really refer to a literal use for agricultural purposes, but as to its “susceptibility to cultivation for agricultural purposes.” A technical term whose usage was known and understood by lawmakers and by the Constitutional Commission during that period, it basically referred to lands not falling under timber or mineral, and thus includes residential lands. Equally telling was the opinion of Secretary of Justice Jose Abad Santos to a 1939 query as to the interpretation of the term in question. The Supreme Court gave great weight to the later Chief Justice's opinion, to wit: Rounding out the Prohibition against Foreign Ownership Seeing as how Article XIII section 1 limits the alienation of public agricultural lands to Filipino citizens, this may easily be circumvented by a simple transfer from a Filipino citizen in favor of an alien. Thus, Section 5 of the same constitution addresses this explicitly. When Sections 1 and 5 are read together, it is therefore clear that aliens are prohibited from acquiring lands in the Philippines, subject to exceptions provided by law. The penned decision referred to the Constitutional Convention, specifically the report of the Committee on Nationalization and Preservation of Lands and other Natural Resources, for the purpose behind the principle: This is further supported by the CA 141, which blocked out the right of aliens from acquiring property by reciprocity; previously granted them by the Public Land Act No. 2874 sections 120 and 121. The Supreme Court affirmed the act of the Register of Deeds in denying the registration of Krivenko's land, and established itself as a landmark case when addressing the issue of foreign ownership of lands within the jurisdiction of the Philippines. Jurisprudence The case of Nicolas and Sinforoso Mercado against Benito Go Bio began as a suit “brought in the Court of First Instance of Manila (civil case No. 55449), to annul a contract of sale and another of lease on two parcels of land with improvements thereon, on the ground that the deed of sale purporting to convey to the defendant the parcels of land and improvements is not a sale with the right to repurchase but a mortgage to secure the payment of a loan.” A settlement was agreed upon on that case on June 24, 1940. An execution of judgment was filed by Bio and