Case Digest (G.R. No. 73002)
Facts:
The Director of Lands v. Intermediate Appellate Court and Acme Plywood & Veneer Co., Inc., G.R. No. 73002, December 29, 1986, the Supreme Court En Banc, Narvasa, J., writing for the Court. The Director of Lands petitioned by certiorari to the Supreme Court from a judgment of the Intermediate Appellate Court that affirmed the Court of First Instance (CFI) of Isabela's order to register five parcels (totaling about 481,390 sq. m.) in favor of Acme Plywood & Veneer Co., Inc. (Acme). Acme had purchased the parcels on October 29, 1962 from Mariano and Acer Infiel, members of the Dumagat tribe.At the CFI, Acme sought confirmation of title under Section 48 of Commonwealth Act No. 141 (The Public Land Act), as amended. The trial court found (and the Intermediate Appellate Court affirmed) that the Infiels and their predecessors had possessed the land from time immemorial, satisfying the 30‑year statutory requirement; that Acme's possession since 1962 was continuous, adverse and public (tacking the Infiels’ possession); that Acme had made extensive improvements (valued at more than P45,000,000) and had donated part of the land for the townsite of Maconacon, Isabela; and that Acme, a duly registered Philippine corporation, could lawfully acquire the land under its corporate purposes.
The sole contention pressed by the Director of Lands on appeal was legal: because Acme's confirmation petition was filed only on July 17, 1981 (well after the 1973 Constitution took effect), Article XIV, Section 11 of the 1973 Constitution — which prohibits private corporations from holding alienable lands of the public domain except by limited lease — should bar registration in Acme’s name. The Director did not dispute the factual findings of ancestral possession, length of occupation or improvements.
The Supreme Court considered whether (a) the lands had ceased to be public domain by operation of law due to long possession under Section 48(b) of the Public Land Act so that they were private when Acme bought them in 1962, and (b) if not, whether the 1973 Constitution's prohibition could retroactively defeat rights arising before its effectivity. The Court reviewed ea...(Subscriber-Only)
Issues:
- Under Section 48(b) of Commonwealth Act No. 141 and the governing precedents, did the ancestral and long possession by the Infiels cause the lands to cease being public domain and become private property ipso jure prior to Acme’s 1962 purchase?
- If the lands had not become private prior to 1962, did the 1973 Constitution, Article XIV, Section 11, which was in force when Acme filed confirmation proceedings in 1981, bar registration in favor of Acme or otherwise operate retroactively to defeat vested rights?
- Should the Court continue to follow the contrary rule in Manila Electric Company v. Castro‑Bartolome (Meralco) (114 SCRA 799), which had held that a corporation could not apply for co...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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