Introduction

Philippine law is among the most restrictive in Asia on foreign ownership of land. The basic rule is simple: foreigners cannot own land in the Philippines. That rule, however, sits inside a larger framework that includes the Constitution, statutes, administrative practice, corporate law, succession law, condominium law, long-term leases, and nationality rules for corporations. Because of that, many transactions that look permissible at first glance can later be challenged as void, simulated, or prohibited.

This article explains the full legal framework in Philippine context: what foreigners may and may not own, what kinds of rights they can legally hold, how corporations are treated, what exceptions exist, what structures are risky or invalid, and what practical consequences follow.

I. The Constitutional Rule: Why Foreigners Cannot Own Land

The starting point is the 1987 Philippine Constitution, particularly the provisions on the national economy and patrimony. The Constitution reserves ownership of lands of the public domain and, by long-standing legal policy, ownership of private lands, to:

Filipino citizens, and
corporations or associations at least 60% owned by Filipinos.

In practice, this means:

a foreign natural person cannot acquire ownership of Philippine land;
a foreign corporation cannot own Philippine land;
a Philippine corporation with more than 40% foreign ownership cannot own Philippine land.

This rule is rooted in national patrimony policy. Philippine land is treated not merely as an economic asset, but as a resource reserved for Filipinos except in narrow situations recognized by law.

The constitutional limitation applies whether the land is:

agricultural,
residential,
commercial,
industrial, or
otherwise privately titled land.

The common misunderstanding is that only “public land” is restricted. That is incorrect in ordinary transactional practice. A foreigner is generally prohibited from acquiring ownership of land itself, whether public or private.

II. What a Foreigner Cannot Own

A foreigner cannot legally acquire:

1. Ownership of land in his or her own name

A deed of sale transferring land directly to a foreign individual is generally void.

2. Ownership through a corporation that is not at least 60% Filipino-owned

A corporation formed in the Philippines is not automatically qualified to own land. Nationality is determined by ownership structure. If Filipino ownership falls below the constitutional threshold, the corporation cannot validly own land.

3. Beneficial ownership disguised behind a Filipino nominee

Arrangements where a Filipino “holds” title for a foreigner, but the foreigner supplies the money and remains the true beneficial owner, are legally dangerous and typically prohibited. These are often attacked as violations of constitutional policy and anti-dummy rules.

4. Ownership through private side agreements that separate title from “real ownership”

Contracts stating that the Filipino registered owner holds land “in trust” for a foreigner, or promising later transfer once convenient, are generally unenforceable if their purpose is to circumvent the constitutional prohibition.

5. Indirect ownership through simulated debt, option, or control structures

Even if title is placed in a Filipino’s name, any arrangement effectively giving the foreigner ownership, control, or the right to compel transfer can be invalid if it amounts to prohibited foreign land ownership.

III. The Core Distinction: Land Ownership vs. Building Ownership vs. Use Rights

One of the most important concepts in Philippine property law is that land ownership is not the same as ownership of improvements or the right to use land.

A foreigner may be prohibited from owning land, but may still lawfully hold certain rights such as:

ownership of a house or building in some lawful arrangements,
a leasehold right over land,
a condominium unit subject to statutory limits,
rights as a mortgagee/lender,
inheritance rights in certain cases,
contractual rights to occupy or develop land.

This distinction matters because many lawful structures for foreigners in the Philippines are built around use, occupation, development, or ownership of improvements, rather than ownership of the land itself.

IV. Ownership of Houses and Improvements by Foreigners

A foreigner may, in some settings, own a building or house without owning the land beneath it.

This typically occurs where:

the land is leased from a Filipino owner or a qualified Philippine corporation; and
the foreigner constructs improvements on the leased property under a valid lease agreement.

In such a case:

the foreigner does not own the land;
the foreigner may own the structure, subject to the terms of the lease and accession-related rules;
the lease contract should clearly define ownership of improvements, rights upon expiration, reimbursement, removal rights, and turnover rules.

The legal and practical problem is that building ownership without land ownership is only as secure as the underlying lease and contract documentation. If the lease expires, is void, or is breached, the foreigner’s practical control over the improvement may be severely limited.

V. The Main Exceptions: When a Foreigner May Legally Hold Rights Connected to Land

Although the general rule is prohibition, Philippine law recognizes a limited number of lawful pathways.

1. Acquisition by hereditary succession

A foreigner may acquire land by hereditary succession. This is the clearest and most widely recognized exception.

This generally means acquisition by operation of succession law upon death, not by sale. The foreign heir may receive rights to land as an heir, subject to the nature of the succession and settlement process.

Important points:

this is an exception to the general ban;
it is most safely understood in the context of legal succession upon death, not as a disguised inter vivos transfer;
disputes often arise if parties try to characterize a sale, donation, simulated transfer, or estate-planning device as “succession.”

The scope of “hereditary succession” has been litigated, and the safest reading is that the exception applies where land passes by reason of death under succession law, rather than through an ordinary conveyance.

2. Ownership of condominium units

Foreigners may own condominium units under the Condominium Act, but not the underlying land in the ordinary sense. The rule is that foreign ownership in the condominium project must not exceed 40% of the total and outstanding capital stock of the condominium corporation, or the corresponding foreign participation must remain within the legal cap depending on the project structure.

In practice:

a foreigner may purchase a condominium unit if the project remains within the foreign ownership ceiling;
the foreigner acquires unit ownership and an appurtenant interest consistent with condominium law;
this is not the same thing as owning a lot or parcel of land outright.

A townhouse project marketed as a “condo” must still be carefully checked. The legal nature of the project matters. A mislabeled development does not create foreign ownership rights if the legal structure is actually a land transfer.

3. Long-term lease of private land

Foreigners may lease private land from Filipino owners or qualified Philippine corporations.

This is one of the most common lawful structures. The lease may cover residential, commercial, tourism, or industrial use, subject to applicable law, zoning, and lease rules.

Long-term lease laws have historically allowed extended lease periods, especially for investors, commonly structured as:

an initial long-term period, with
a possible renewal for another long-term period,

subject to the governing statute and the exact transaction type.

A lease grants possession and use, not ownership. It may still be economically valuable, but it does not convert into land ownership merely because the term is long.

4. Acquisition by former natural-born Filipino citizens, within statutory limits

Former natural-born Filipinos who lost Philippine citizenship may, under special laws, acquire limited areas of private land for specified purposes, such as residential use and, under some legal frameworks, business or commercial purposes, subject to area caps and statutory conditions.

This is not a general foreigner exception for all foreigners. It is a special privilege for a distinct class:

those who were natural-born Filipinos, and
later lost Philippine citizenship.

This category is often confused with “dual citizens” and ordinary foreigners. The distinction matters greatly.

5. Dual citizens / reacquired citizens

A person who has reacquired or retained Philippine citizenship under Philippine citizenship laws is no longer treated simply as a foreigner for this purpose. A Philippine citizen, including a dual citizen recognized by law, may generally own land as a Filipino, subject to ordinary property and registration rules.

This is often the legally cleanest path for former Filipinos with foreign passports: reacquire or retain Philippine citizenship first, then transact as a Philippine citizen.

VI. Former Natural-Born Filipinos: Special Rights to Acquire Land

A former natural-born Filipino is in a unique category under Philippine law. Even after losing Philippine citizenship, such a person may still acquire private land within statutory limits.

These rules are narrower than many assume.

Key features of this special regime

A former natural-born Filipino may generally acquire private land:

for residential purposes, up to statutory maximum areas; and
in some cases for business or commercial purposes, again within legal limits.

The exact area limits depend on the law invoked and the purpose of acquisition. Historically, the limits have been framed differently for:

urban land, and
rural land.

Because these are statutory privileges, strict compliance matters. The acquisition must fall within:

the authorized purpose,
the area limit,
the legal identity of the buyer as a former natural-born Filipino.

A spouse who is purely foreign does not automatically share the same privilege independently.

VII. Dual Citizenship and Land Ownership

The legal result changes substantially if the person is a dual citizen or has reacquired Philippine citizenship.

A former Filipino who validly reacquires Philippine citizenship is generally treated as a Filipino citizen for purposes of land ownership. This means the constitutional ban on foreign ownership is no longer the same obstacle, because the person is again a Philippine citizen.

This area is often misunderstood in practice:

A former Filipino who remains solely foreign is still subject to foreign ownership restrictions, except for the special statutory privileges.
A former Filipino who has reacquired Philippine citizenship can generally buy land as a Filipino.

The proof of citizenship status at the time of acquisition is critical. Documentation should be complete and current, because registry, bank, tax, and notarial compliance all depend on it.

VIII. Condominium Ownership: The Most Common Lawful Purchase by Foreigners

For many foreigners, the only straightforward real property purchase available is a condominium unit.

Why condos are treated differently

In condominium ownership, the buyer acquires a unit and a proportional interest structured through condominium law. The project must observe the constitutional and statutory foreign ownership caps. Because the law specifically allows this structure, it is the most familiar lawful exception to the land ownership ban.

Major limits and practical issues

A foreigner still cannot buy without checking:

whether the project is legally registered as a condominium;
whether the foreign ownership ceiling has already been reached;
whether the seller has clean title;
whether common areas and condominium corporation rights are in order;
whether the project is a true condo regime rather than a disguised subdivision lot sale.

The fact that a developer is willing to sell to a foreigner does not itself prove legality. The project documents and foreign ownership ratio matter.

IX. Leasehold Rights: The Main Functional Alternative to Ownership

Because land ownership is restricted, long-term leasing is the principal lawful alternative.

What a foreigner can do under a lease

A foreigner may typically:

possess the property during the lease term,
build improvements if allowed,
use the land for residence or business,
assign or sublease only if the lease permits,
register the lease if registrable and if registration requirements are met.

Why lease drafting is crucial

For foreigners, the lease often carries most of the economic value of the arrangement. Poor drafting can destroy that value. Important provisions usually include:

precise term and renewal terms,
rental escalation,
permitted use,
rights to construct improvements,
ownership of improvements,
tax allocation,
repair and maintenance duties,
default remedies,
assignment and sublease rights,
effect of death or sale by the lessor,
annotation or registration where applicable,
dispute resolution and governing law.

A long-term lease is lawful; a lease that is actually a disguised sale can still be struck down.

X. Corporations and Land Ownership: The 60-40 Rule

Philippine corporations may own land only if they qualify as Philippine nationals for constitutional purposes, usually meaning at least 60% Filipino-owned.

A. Basic rule

A corporation must be at least:

60% owned by Filipino citizens, and
not merely on paper.

B. Why “paper compliance” is not enough

Philippine law does not permit foreigners to evade the Constitution by placing nominal Filipino shareholders who do not have real beneficial ownership or control. Authorities and courts may look at the substance of ownership and control.

C. Control and capital issues

Questions may arise as to:

voting rights,
beneficial ownership,
classes of shares,
financing arrangements,
veto rights,
board composition,
shareholder agreements,
nominee arrangements.

Where a structure gives foreigners effective ownership or control beyond what the Constitution allows, it may be challenged.

D. The “60-40” limit is not a universal safe harbor

Even if a corporation appears 60% Filipino-owned, the arrangement may still be legally vulnerable if:

Filipino ownership is simulated,
funds came entirely from foreigners under a sham arrangement,
Filipinos are mere fronts,
control rights are contractually shifted to foreigners in substance.

This is why landholding structures should be tested not only for arithmetic compliance, but for constitutional substance.

XI. Anti-Dummy Concerns and Nominee Structures

The Philippines has long enforced anti-circumvention policy through what is commonly referred to as the Anti-Dummy Law and related constitutional doctrine.

What the law targets

The law targets schemes where:

foreigners use Filipino citizens as fronts;
foreigners intervene in the management, operation, or control of a nationalized activity beyond what the law permits;
foreigners obtain rights prohibited by the Constitution through nominally Filipino entities.

In the land setting, red flags include:

title in a Filipino’s name but purchase money wholly from a foreigner under a concealed trust;
secret agreements giving the foreigner the right to demand transfer;
voting structures that strip Filipinos of meaningful control;
side agreements granting foreigners effective dominion over landholding corporations;
mortgages, options, management contracts, or debt structures used as disguised ownership devices.

Consequences

Possible consequences include:

void contracts,
inability to enforce side agreements,
exposure to civil and criminal liability in some cases,
loss of money paid,
title disputes,
tax and registration complications.

The practical lesson is severe: a foreigner who knowingly structures around the prohibition may have no judicial protection when the arrangement unravels.

XII. Marriage to a Filipino Does Not Give Land Ownership Rights

A very common misconception is that marrying a Filipino allows a foreign spouse to own land. It does not.

What marriage does not do

Marriage to a Filipino:

does not convert a foreign spouse into a Filipino citizen;
does not create an exception to the constitutional ban;
does not allow land to be titled jointly in a way that gives the foreign spouse land ownership.

What may happen in practice

If land is acquired during marriage and the Filipino spouse is legally capable of owning it, ownership questions may become complicated by family property regimes. But constitutional policy still prevents land ownership from vesting in the foreign spouse in a prohibited way.

Thus:

land may be titled in the Filipino spouse’s name;
the foreign spouse may have certain marital or economic interests depending on the property regime and facts;
but that is not the same as lawful direct foreign ownership of land.

Trying to place the foreign spouse’s name on title as co-owner is not a lawful shortcut.

XIII. Inheritance, Succession, and Foreign Heirs

Inheritance is one of the few genuine exceptions, but it requires careful handling.

1. Hereditary succession is recognized

A foreigner may inherit land. This usually arises where:

the decedent owned Philippine land lawfully; and
the foreigner becomes an heir under succession law.

2. Important distinction: inheritance vs. sale

The exception does not authorize:

a lifetime sale to a foreigner,
a donation used to simulate succession,
a device intended to avoid the constitutional ban.

3. Estate settlement issues

Even where inheritance is allowed, the foreign heir still must navigate:

estate settlement,
probate or extrajudicial settlement rules,
taxes,
partition,
land registration and transfer documentation,
possible compulsory heir issues under Philippine succession law.

4. Co-heir and partition complications

If the foreigner inherits together with Filipino heirs, partition and transfer issues can become sensitive. The foreign heir’s rights may exist, but the mechanics of title settlement can be complex.

XIV. Mortgages, Foreclosure, and Creditor Rights

Foreigners may have roles as lenders or creditors, but land ownership restrictions still matter.

A foreign individual or foreign entity may, depending on the structure and applicable law, hold certain security interests or creditor rights. But the right to own land following enforcement is constrained by the constitutional ban.

Where a foreign mortgagee forecloses, the law does not simply allow unrestricted retention of land ownership if constitutional nationality restrictions are violated. The details depend on the exact instrument, the parties, and the enforcement route.

This is an area where parties often overestimate what a foreign lender can ultimately keep. Security rights do not automatically override constitutional land ownership restrictions.

XV. Public Land vs. Private Land

Philippine land law distinguishes public land from private land, but for foreigners the practical restriction remains broad.

Public land

Lands of the public domain are strongly reserved to Filipinos and qualified Filipino-controlled entities. Foreign ownership is not allowed.

Private land

Even privately titled land is generally not transferable to foreigners by sale. The Constitution and related property doctrine prevent foreigners from acquiring ownership of private land except in the narrow recognized exceptions.

So while legal analysis may distinguish public and private land, the foreign buyer of land usually reaches the same bottom line: no ownership by ordinary purchase.

XVI. What Transactions Are Commonly Void or Vulnerable

Many problematic transactions share one feature: they try to achieve indirectly what the Constitution forbids directly.

Examples include:

1. Direct sale of land to a foreigner

Usually void.

2. Simulated sale to a Filipino partner with secret trust for foreign buyer

Highly vulnerable and often illegal in purpose.

3. Filipino corporation with sham Filipino shareholders

Vulnerable to challenge under constitutional and anti-dummy principles.

4. “Loan” secured by land with hidden transfer obligation

May be attacked as a disguised sale or prohibited circumvention.

5. Irrevocable special power of attorney enabling foreign beneficial control

Risky where it effectively substitutes for ownership.

6. Long lease with terms that amount to perpetual ownership in disguise

A lease may be valid; a sham sale disguised as lease may not be.

7. Side agreements promising future transfer when “law changes”

Such promises may be unenforceable if tied to a prohibited present arrangement.

XVII. Can a Foreigner Recover Money Paid Under an Illegal Land Deal?

This is one of the harshest areas in practice.

If a foreigner knowingly enters into a prohibited land acquisition scheme, courts may refuse relief under doctrines relating to illegality and public policy. In plain terms, the foreigner may be unable to compel transfer and may also struggle to recover the money.

The legal system does not reward circumvention of the Constitution. Outcomes depend on facts, fault, equity, and the exact structure, but the risk of financial loss is real and substantial.

This is why “everyone does it” is not legal protection.

XVIII. Registration Does Not Cure an Illegal Transaction

Another dangerous misconception is that once a deed is notarized and a title is issued or transferred, the problem is solved. It is not.

If the underlying transfer is constitutionally prohibited:

registration does not validate a void transaction;
title documents do not necessarily cure illegality;
later disputes may still expose the invalidity of the transaction.

In Philippine property law, the legitimacy of title often depends on the validity of the underlying acquisition.

XIX. Tax Declarations, Possession, and Improvements Are Not Ownership

Foreigners sometimes believe that paying taxes, holding a tax declaration, occupying land for years, fencing property, or building a house creates ownership. These facts may matter evidentially, but they do not override constitutional disqualification.

A foreigner cannot become lawful landowner simply by:

paying real property taxes,
possessing the land,
making improvements,
having local documents or barangay certifications,
placing the property under a corporation that is not constitutionally qualified.

Tax compliance is not a substitute for legal capacity to own land.

XX. Long Possession and Prescription

Philippine law recognizes acquisitive prescription in some contexts, but foreigners cannot rely on prescription to defeat constitutional restrictions on land ownership. A person legally disqualified from owning land cannot ordinarily perfect title by a route that would undermine the Constitution.

Thus, long occupancy does not solve the nationality problem.

XXI. Usufruct, Easements, and Other Real Rights

Even if ownership is restricted, foreigners may still in appropriate cases hold or benefit from rights less than ownership, depending on the legal instrument and the facts.

These may include:

leasehold rights,
usufructuary arrangements,
easements,
certain contractual occupancy rights,
rights over improvements,
financing and security rights.

But each must be evaluated carefully. A permissible limited right becomes problematic when it is structured to transfer the substance of land ownership.

XXII. Special Issues in Family Property Regimes

When a foreigner is married to a Filipino, Philippine family law and property regime rules may complicate the economic analysis, but they do not erase the constitutional prohibition.

Issues that commonly arise:

whether land acquired during marriage forms part of the conjugal or community regime;
how to characterize funds used for purchase;
whether the foreign spouse can claim reimbursement or beneficial interest;
what happens on death, separation, or annulment;
how inheritance interacts with the constitutional ban.

The safest legal point remains the same: the foreign spouse does not acquire prohibited land ownership merely through the marriage or the family property regime.

XXIII. Developers, Sales Agents, and Informal Assurances

Foreign buyers are often told one of the following:

“You can just put it in your spouse’s name.”
“We’ll make a side agreement.”
“You own the house, so it’s basically yours.”
“We do this for foreigners all the time.”
“We’ll set up a corporation and make Filipinos shareholders.”
“A 50-year lease is the same as owning.”

These statements are often misleading or legally incomplete.

Philippine land restrictions are not defeated by market custom, broker confidence, private memoranda, or informal assurances. If a structure is prohibited, widespread use does not legalize it.

XXIV. Foreign Investment and Land: What Investors Need to Understand

Foreign investors may invest in businesses in the Philippines, but landholding remains a controlled area.

A foreign investor may:

own shares in a corporation, subject to sectoral limits;
lease land for project use;
participate in developments through contracts;
own condominium units within legal caps;
structure operations around lawful possession rather than land ownership.

A foreign investor generally may not:

own land directly as an individual;
use a majority-foreign corporation to own land;
use nominee structures to bypass nationality rules.

Investment law does not nullify constitutional land restrictions.

XXV. Indigenous Peoples, Ancestral Lands, Agrarian Reform, and Other Sensitive Categories

The topic becomes even more restricted where land is affected by:

agrarian reform law,
ancestral domain or ancestral land claims,
forest land classification,
protected areas,
foreshore or coastal regulation,
zoning and environmental restrictions.

In those situations, the question is not merely whether the buyer is foreign. The land itself may be subject to further legal disabilities, classifications, or public-interest limits. A transaction involving foreigners in such contexts carries additional layers of risk.

XXVI. Local Government, Zoning, and Regulatory Compliance

Even where a foreigner acquires a lawful right short of ownership, such as a lease or condominium unit, the project must still comply with:

zoning ordinances,
building code rules,
fire safety regulations,
environmental laws,
tax requirements,
homeowners’ or condominium rules,
business permit requirements where applicable.

Nationality compliance is only one part of legality.

XXVII. Common Lawful Structures for Foreigners

The legally safer structures in the Philippines are usually these:

1. Condominium ownership

Best for outright purchase where the project is legally compliant and foreign ownership cap has not been exceeded.

2. Long-term lease of land

Best for residence, resort use, or business operations where control and use are more important than fee ownership.

3. Ownership of improvements on leased land

Useful where the foreigner wants a home or facility without land ownership.

4. Acquisition through hereditary succession

Available only where succession law genuinely applies.

5. Purchase by a former natural-born Filipino under special law

Available only to that legally defined class and within statutory limits.

6. Acquisition after reacquisition of Philippine citizenship

Often the cleanest route for former Filipinos who qualify.

XXVIII. Common Unlawful or High-Risk Structures

The highest-risk arrangements are usually:

buying land in a Filipino friend’s name under a secret trust;
buying through a romantic partner without legal safeguards;
creating a corporation with nominal Filipino shareholders who are mere fronts;
using undated deeds, blank documents, or side letters;
relying on powers of attorney to simulate ownership;
entering “lease” contracts that are actually installment sales;
signing contracts drafted by brokers instead of competent Philippine counsel;
paying the full purchase price before verifying legal capacity and title status.

These arrangements fail most often when:

relationships sour,
heirs appear,
the Filipino titleholder dies,
taxes go unpaid,
the property is sold again,
creditors intervene,
the foreigner attempts enforcement.

XXIX. Remedies and Litigation Realities

When disputes arise, Philippine courts look closely at:

the Constitution,
nationality of the parties,
the real nature of the transaction,
whether the parties attempted circumvention,
whether the contract is void for illegality or public policy,
whether succession law applies,
whether the party claiming ownership had legal capacity to acquire it.

A foreign claimant who knowingly participated in a prohibited arrangement may face severe remedial limits. Courts are not obliged to rescue a party from a void scheme designed to evade constitutional policy.

XXX. Practical Due Diligence in Philippine Context

For any foreigner dealing with real property in the Philippines, the legal analysis should begin with one question:

Is this transaction transferring land ownership, or only a lawful right connected to land?

Then verify:

the buyer’s citizenship status;
whether the buyer is a former natural-born Filipino or dual citizen;
whether the asset is land, condominium, or leasehold;
whether the seller has valid title;
whether the project is a true condominium regime;
whether the corporation involved is at least 60% Filipino-owned in substance and form;
whether any anti-dummy or nominee issue exists;
whether the property is subject to agrarian, ancestral, environmental, or zoning restrictions;
whether all tax, registration, and documentary rules are met.

The legality of the buyer’s capacity is as important as the cleanliness of the title.

XXXI. Bottom-Line Rules

In Philippine law, the most important rules are these:

Foreigners generally cannot own land in the Philippines.
Marriage to a Filipino does not create a right to own land.
Using a Filipino nominee or sham corporation is legally dangerous and often void.
Foreigners may lawfully own condominium units, subject to the 40% foreign cap in the project structure.
Foreigners may lawfully lease land, often on long-term terms allowed by law.
Foreigners may own buildings or improvements in some lawful lease-based arrangements, but not the land underneath.
Foreigners may acquire land by hereditary succession.
Former natural-born Filipinos may acquire limited private land under special laws.
Those who reacquire Philippine citizenship may generally own land as Filipino citizens.
Registration, possession, payment of taxes, or private side agreements do not validate a constitutionally prohibited transfer.

Conclusion

The Philippine legal framework does not merely regulate foreign land ownership; it largely prohibits it, except in narrow and carefully defined situations. The law draws a firm line between ownership of land and other interests such as leasehold, condominium ownership, inheritance rights, and ownership of improvements. That distinction defines what foreigners can legally do.

For ordinary foreign nationals, the lawful paths are limited but real: condominium ownership, long-term leasing, certain rights over improvements, and inheritance by hereditary succession. For former natural-born Filipinos and reacquired citizens, the law is more favorable, but status and statutory compliance are crucial.

The central lesson in Philippine context is that land nationality rules are substantive, not technical. A structure that appears workable in business terms can still be void if it defeats constitutional policy. In this field, the safest transaction is the one that respects the basic rule from the outset: foreigners may hold some property rights in the Philippines, but ownership of land itself is generally reserved to Filipinos and qualified Filipino-controlled entities.