Case Digest (G.R. No. 54952)
Facts:
Republic of the Philippines (represented by the Director of Lands) v. Iglesia ni Cristo, with its Executive Minister Erano G. Manalo as Corporation Sole, and Hon. Gabriel O. Valle, Jr. as Presiding Judge, Court of First Instance of Ilocos Norte, Branch II, G.R. No. L-54952, March 05, 1984, Supreme Court Second Division, De Castro, J., writing for the Court.On August 7, 1979, Iglesia ni Cristo (INC) filed in the Court of First Instance of Ilocos Norte an application for registration of a 614-square-meter parcel in San Pedro, Vintar, Ilocos Norte under the Property Registration Decree (P.D. 1529), alleging acquisition by a deed of sale dated April 10, 1978 from Carmen Racimo and alleging predecessor possession in excess of thirty years. The application invoked Section 14 of P.D. 1529 (persons who may apply for registration, including those who acquired private lands by prescription).
The Republic (Director of Lands) opposed, alleging among other grounds that the land remained part of the alienable public domain, that the applicants and their predecessors had not possessed the land since June 12, 1945 as required under Section 48(b) of the Public Land Law (Commonwealth Act No. 141, as amended), that a confirmation under Section 48(b) had not been filed, and that a private corporation — here, the Iglesia ni Cristo as a corporation sole — was constitutionally disqualified from owning alienable public lands under Section 11, Article XIV of the 1973 Constitution. The Republic also argued noncompliance with the deadline under P.D. 892 for asserting Spanish titles.
On July 23, 1980 the trial court (Court of First Instance) ruled for INC, holding that INC as a corporation sole is not within the contemplation of Section 11, Article XIV of the 1973 Constitution and that it could qualify to register the parcel pursuant to Section 14 of P.D. 1520 (as the trial court characterized the enabling decree). The Republic sought review in the Supreme Court by a petition for review, which the Court gave due course.
The Supreme Court (Second Division) reversed the trial court, following its prior decision in Republic v. Judge Candido P. Villanueva, 114 SCRA 875 (June 29, 1982), and subsequent related rulings, concluding that INC as a corporation sole is disqualified to acquire or hold alienable public domain lands and that the parcel remained public land absent a judicial confirmation under Section 48(b). The Court...(Subscriber-Only)
Issues:
- Is the Iglesia ni Cristo, as a corporation sole, qualified to apply for registration of the 614 sq. m. parcel given the prohibition in Section 11, Article XIV of the 1973 Constitution against private corporations holding alienable public domain lands?
- Did the land in question cease to be public domain so as to permit registration under Section 14 of P.D. 1529 (or under the Land Registration Act) absent a judicial confirmation under...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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