G.R. No. L-59447 and G.R. No. L-60188, December 27, 1982
Republic of the Philippines, represented by the Director of Lands and the Director of Forest Development, petitioner, vs. Honorable Court of Appeals and Iglesia Ni Cristo, represented by its Executive Minister Erano G. Manalo, respondents.

FACTS

These consolidated cases involve applications for land registration filed by the Iglesia Ni Cristo (INC), a corporation sole, under Section 48(b) of the Public Land Act. INC sought judicial confirmation of its title over certain parcels of land, claiming open, continuous, exclusive, and notorious possession for at least thirty years. The lower courts granted the applications, prompting the Republic to appeal. The Republic argued that the constitutional prohibition against private corporations holding alienable lands of the public domain, except by lease, bars INC’s registration.

ISSUE

The primary issue is whether INC, as a corporation sole, may register and hold title to alienable lands of the public domain under Section 48(b) of the Public Land Act, in light of constitutional restrictions.

RULING

The Supreme Court ruled in favor of the Republic and dismissed INC’s applications. The Court held that a corporation sole, being a juridical person, is disqualified from acquiring alienable lands of the public domain by virtue of the constitutional prohibition. Furthermore, the benefits of Section 48(b) of the Public Land Act, which allows confirmation of imperfect titles based on possession, apply only to Filipino citizens or natural persons. The Court rejected the argument that the lands had become private, noting that a registration proceeding under Section 48(b) presupposes the land is still part of the public domain. The possession claimed by INC merely gives rise to an inchoate right (derecho dominical incoativo) until the state issues a certificate of title. Following its precedent in Republic vs. Villanueva, the Court found no merit in the applications and set aside the lower courts’ decisions.