Title
Republic vs. Intermediate Appellate Court
Case
G.R. No. 75042
Decision Date
Nov 29, 1988
The Roman Catholic Bishop of Lucena sought title confirmation for four parcels of land, claiming ownership through purchase, donation, and decades of possession. The Supreme Court ruled the lands were private property due to acquisitive prescription, affirming the corporation sole's right to hold property for religious purposes.
corporation sole
confirmation of title
parcels of land
A

Case Digest (G.R. No. 75042)

Facts:

  • Background and Procedural History
    • The case is an appeal from the decision of the First Civil Cases Division of the then Intermediate Appellate Court affirming the Court of First Instance of Quezon’s decision ordering registration of title to four parcels of land.
    • The parcels include three lots (Lots 1, 2, and 3) under plan PSU-65686 and one lot under plan PSU-112592, all claimed by the Roman Catholic Bishop of Lucena, represented by Msgr. Jose T. Sanchez.
    • A Motion for Reconsideration by the appellant (Republic of the Philippines) challenging the registration was filed and subsequently denied for lack of merit.
  • Factual Background of the Land Acquisition
    • Application and Possession
      • On February 2, 1979, the Roman Catholic Bishop of Lucena filed an application for confirmation of title to four parcels of land.
      • The application claimed title through purchases and donations dating as far back as 1928.
      • The required legal formalities, such as publication, posting, and notification of the proper government officials, were duly complied with.
    • Description and Acquisition of the Parcels
      • Lots 1, 2, and 3 (Plan PSU-65686):
        • Lot 1 measured 18,977 square meters, acquired by purchase in 1928 through Rev. Father Raymundo Esquenet.
ii. Lot 2 was partly purchased in 1969 and partly already owned by the Church before the 1928 survey. iii. Lot 3, measuring 16,221 square meters, had been in the Church’s possession, used as a cemetery since as early as 1918. iv. These lots were recorded for taxation as a cemetery site, supporting continuous and public possession.
  • Fourth Parcel (Plan PSU-112592):
    • Located in Barrio Bucal (Taguan), measured 3,221 square meters, and was previously owned by private individuals.
ii. The lot was donated to the Church on February 26, 1941, and surveyed in 1940 with the corresponding plan approved in 1941. iii. An old chapel was demolished and replaced with a new chapel on this lot.
  • Possession and Presumptive Ownership
    • The continuous, public, peaceful, and adverse possession of the Church over the four parcels was established:
      • Over 52 years of possession for Lots 1 and 2 (from the survey in 1928).
ii. About 62 years of possession for Lot 3. iii. More than 39 years of possession for the fourth parcel (from the survey in 1940).
  • Based on these facts, the lower courts held that the possession satisfied the requisites of acquisitive prescription, effectively converting the public domain lands into private property in the name of the Roman Catholic Bishop of Lucena.
  • Proceedings and Arguments
    • Lower Court Decisions
      • The Court of First Instance ordered the registration of the title to the four parcels in the name of the Roman Catholic Bishop of Lucena, Inc.
      • The Intermediate Appellate Court affirmed this decision and later denied the appellant’s Motion for Reconsideration.
    • Grounds for Appeal by the Republic of the Philippines
      • Alleged violation of Article XIV, Section 11 of the 1973 Constitution, which prohibits private corporations from acquiring alienable lands of the public domain.
      • The contention that the application for registration was ineffectual because it was filed after the Constitution took effect (January 17, 1973).
      • Additional errors: prior registration of the lands in a previous case and the failure of the respondent to clearly establish the identity of the properties.
    • Position of the Parties
      • The petitioner (Republic) argued that as a corporation sole, the Roman Catholic Bishop of Lucena should be treated as a private corporation and hence disqualified from owning alienable public lands.
      • The respondent maintained that the Church’s continuous possession converted the lands into private property and that a corporation sole is not to be treated as an ordinary private corporation for the purposes of the constitutional prohibition.

Issues:

  • Issue on Eligibility
    • Whether the Roman Catholic Bishop of Lucena, operating as a corporation sole, is qualified to apply for confirmation of its title to the four parcels of land.
    • Whether a corporation sole should be treated as an ordinary private corporation for the application of Article XIV, Section 11 of the 1973 Constitution.
  • Issue on the Effect of Acquisitive Prescription
    • Whether the long, continuous, public, and adverse possession of the four parcels, as established by the lower courts, can convert public lands into private property.
  • Issue Raised by the Appellant
    • Whether registration is ineffectual because the application was made after the effectivity of the 1973 Constitution, which purportedly bars private corporations from acquiring alienable public lands.
    • Consideration of alleged previous registration and failure to prove the identity of the lands applied for registration.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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