G.R. No. L-56613 March 14, 1988
THE DIRECTOR OF LANDS, petitioner, vs. THE HONORABLE COURT OF APPEALS and IGLESIA NI CRISTO, respondents.

FACTS

On November 28, 1973, private respondent Iglesia ni Cristo (INC), a corporation sole, filed an application for registration of a 379-square-meter parcel of land in Amadeo, Cavite. INC alleged ownership through a 1947 Deed of Absolute Sale and asserted that it and its predecessors-in-interest had been in actual, continuous, public, peaceful, and adverse possession in the concept of owner for over thirty years. The Republic, through the Director of Lands, opposed the application, contending that INC had insufficient title, lacked the required possession, and that the land remained part of the inalienable public domain.
The Court of First Instance of Cavite granted INC’s application, finding continuous, open, and adverse possession for over forty years and noting the land was within a proposed alienable block. The Director of Lands appealed to the Court of Appeals, arguing that INC failed to sufficiently identify the land by not submitting the original tracing cloth plan and that INC was disqualified under the 1973 Constitution from holding alienable lands of the public domain. The appellate court affirmed the decision in toto, prompting this petition for review.

ISSUE

The primary issues are: (1) whether the submission of a certified copy of a white paper plan, instead of the original tracing cloth plan, suffices for identifying the land; and (2) whether INC, as a private corporation, is disqualified from registering the land under the 1973 Constitution.

RULING

The Supreme Court affirmed the Court of Appeals’ decision, finding no reversible error. On the first issue, the Court held that Exhibit “O,” the certified white paper plan, was sufficient for identification. This plan, approved by the Land Registration Commission and reverified by the Bureau of Lands, contained all necessary technical descriptions, boundaries, and location details. The purpose of the tracing cloth requirement is to ensure precise identity and prevent overlaps. This purpose was satisfied here, especially given the land’s small size, location in a poblacion, and the existence of a chapel, making it readily identifiable. The case of Director of Lands v. Reyes was distinguished, as it involved vast, uncultivated tracts where precise survey plans were crucial.
On the constitutional issue, the Court ruled that the 1973 Constitution’s prohibition against private corporations holding alienable public lands did not apply. Applying Section 48(b) of Commonwealth Act No. 141 , as amended, the Court found that INC’s predecessors-in-interest had completed the required thirty years of open, continuous, exclusive, and notorious possession by 1966. Upon completion of this period, the land ceased to be public domain by operation of law and became private land. Consequently, INC acquired a vested right to confirmation of title before the 1973 Constitution took effect. This vested right could not be impaired by the subsequent constitutional prohibition. The petition was denied, and the appellate court’s decision was affirmed in toto.