G.R. No. 16197 - Capiz vs. Ramirez

Central Capiz, a corporation, filed an original action in the Supreme Court seeking an interpretation and application of Act No. 2874 (the "Public Land Act") with regard to its effect on privately owned agricultural lands.
The petitioner’s action was intended to clarify whether the Act’s provisions could apply to lands not held by the government (i.e., lands with private, freehold title).

On or about July 1, 1919, Ana Ramirez contracted with Central Capiz for a thirty-year sugar cane supply from her plantation.
The contract was to be later converted into a right in rem and recorded in the Registry of Property as an encumbrance upon Ramirez’s land, binding future owners.
In the interim, before the contract was converted, Act No. 2874 came into effect.

Ramirez admitted the contract and her subsequent obligation to execute the attendant deed; however, she refused on the grounds that more than 61% of the petitioner’s capital stock was owned by non-citizens.
Under Act No. 2874, if a corporation is not wholly owned by citizens of the Philippine Islands or the United States, restrictions and a penal provision—including nullity of contracts and reversion of property to the government—could be imposed if the land is considered under the Act’s purview.
Both parties conceded that the land at issue is private agricultural land evidenced by a Torrens title.

Whether Act No. 2874 applies exclusively to lands of the public domain or extends its provisions to lands under private ownership.
Inferences drawn from certain sections (notably sections 23, 24, 121, and 122) raised doubts, though these were argued to be inconsistent with the overall legislative intent and constitutional mandates.

Does Act No. 2874 apply solely to agricultural lands of the public domain, or can it be construed to include lands held in private, fee simple (freehold) title?
Can the disputed contract for sugar cane supply, later to be converted into a right in rem, be enforced without triggering the penal provisions intended for transactions involving public lands?

Does the inclusion of the phrase “and for other purposes” in the title of Act No. 2874, in light of the constitutional requirement (as seen in the Jones Law and similar state constitutions) prohibiting bills from embracing more than one subject, provide ground to extend the Act’s scope to private lands?
Is it within the legislative power to apply a law meant for public lands to privately owned lands without conflicting with constitutional mandates regarding legislative subject matter and clarity?