The 1987 Philippine Constitution allows the acquiring of private lands by foreigners through inheritance or succession, which is an exception rather than the general rule. For this reason the Philippine Supreme Court, in construing the primary law, restricted it to a situation where the deceased left no last will and testament. This is to avoid an indirect circumvention of the prohibition on acquisition of private lands by foreigners.
How is this possible? The deceased person may have priorly acquired private lands in the Philippines while he or she was still a Filipino citizen, and then married a foreigner. The other instance is when children are born after the deceased got naturalized and he or she did not apply for re-acquisition of Philippine citizenship.