Topic: Land Acquisition by Private Corporations

OSCAR NATIVIDAD, BARTOLOME RAMOS and EUGENIO PASCUAL petitioners,

vs. THE COURT OF APPEALS and REPUBLIC OF THE PHILIPPINES.
G.R. No. 88233 │ October 4, 1991 GRIÑO-AQUINO, J:

FACTS: [Original Application for Land Title]

In 1982, Tomas Claudio Memorial College, Inc (TCMC) sought for the
registration of title of the six (6) parcels of land which it acquired in 1979. However, the
Director of Lands opposed the same on the grounds, among others, that the subject
lots were public domain which belong to the Republic of the Philippines and cannot be
subject to private appropriation and that TCMC is a private corporation which is not
allowed to own alienable land of the public domain under the Philippine Constitution.

Months later, petitioners Oscar Natividad, Bartolome Ramos and Eugenio

Pascual substituted in the proceedings after they bought the subject lots from TCMC.
They accordingly presented testimonies of several witnesses and other evidences to
prove that the original owners had possessed and cultivated the subject lots for more
than thirty (30) years before they were sold to TCMC. Subsequently, the trial court
ordered the registration of the subject lots, except the portion along a creek which was
reserved to the easement of public use, contending that the applicants have a
registerable title thereto. The Director of Land appealed the said decision and averred,
among others, that the registration of the subject lots in favor of Oscar, Bartolome and
Eugenio who just substituted TCMC in the proceedings was a circumvention of the
constitutional prohibition against private corporations in owning alienable lands of the
public domain.
.
ISSUE:
WHETHER OR NOT TCMC which is a private corporation may, by itself or
through its vendees, register the titles of the subject lots.

RULING:
Yes, the Supreme Court ruled that even if TCMC is a private corporation, it may,
by itself or through its vendees, register the titles of the subjects lots because the
constitutional prohibition against private corporation in owning alienable lands of the
public domain is no longer applicable in its case as the subject lots have already been
converted to private land through acquisitive prescription by TMC’s predecessors-in-
interest. The facts that were established indicated that before TMC acquired the
subject lots, its predecessors-in-interest who acquired and tiled the subject lots as
early as 1937 already had imperfect titles which only need confirmation.

In the case of Director of Lands vs IAC and Acme Plywood & Veneer Co., Inc.,
which was cited in the instant case, the Supreme Court ratiocinated that the defect in
filing the confirmation proceedings in the name of a corporation cannot refute the
substance and merits of the right of ownership sought to be confirmed in said
proceedings covering lands which ceased to be public land and has become private
property.