Case Digest (G.R. No. L-59447)
Facts:
The cases stemmed from applications for land registration filed by Iglesia ni Cristo (INC), a corporation sole, under Section 48(b) of the Public Land Act, to confirm claims and obtain certificates of title for two parcels of land. In G.R. No. L-59447, the Republic of the Philippines, represented by the Director of Lands and the Director of Forest Development, challenged the grant by the lower court, contending that the constitutional prohibition in Article XIV, Section 11 of the 1987 Constitution (as quoted in the text) prevents any private corporation or association from holding alienable lands of the public domain except by lease. The Republic likewise raised an ancillary question concerning the nature of the lands sought to be registered, insisting that they were still public lands subject to the constitutional restriction. In G.R. No. L-60188, the Republic, represented by the Director of Lands, similarly appealed from the lower court’s decision granting INC’s registration a...Case Digest (G.R. No. L-59447)
Facts:
The Republic of the Philippines, represented by the Director of Lands and the Director of Forest Development, elevated two land registration cases from lower courts after Iglesia ni Cristo (INC), a corporation sole, applied for registration of two lots under Section 48(b) of the Public Land Act. The Republic argued that Article XIV, Section 11 of the 1987 Constitution (as invoked in the cases) bars a private corporation or association from holding alienable lands of the public domain except by lease, and it also raised the ancillary issue whether the lands were still public lands.The lower courts granted INC’s applications for confirmation of title and issuance of certificates of title, prompting the Republic to seek review; a dissent emphasized that the applications should not have been decided on the basis of pending or not yet final precedents and raised constitutional concerns affecting INC’s religious freedom and equal protection.
Issues:
- Whether INC, as a corporation sole, may be allowed to register alienable agricultural lands of the public domain under Section 48(b) despite Article XIV, Section 11’s prohibition on corporations holding such lands except by lease.
- Whether the lands sought to be registered are public lands such that Section 48(b) applies.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)