G.R. No. L-46729 November 19, 1982
LAUSAN AYOG, et al., petitioners, vs. JUDGE VICENTE N. CUSI, JR., Court of First Instance of Davao, Branch I, PROVINCIAL SHERIFF OF DAVAO, and BINAN DEVELOPMENT CO., INC., respondents. MINISTER OF NATURAL RESOURCES and DIRECTOR OF LANDS, intervenors.

FACTS

On January 21, 1953, the Director of Lands awarded Cadastral Lot No. 281 in Davao to Biñan Development Co., Inc. through a sales application. Some occupants protested, but the Director dismissed their protests in 1957, ordering them to vacate as they were found to be squatters who entered after the award. No appeal was taken. Due to the occupants’ refusal to leave, the corporation filed an ejectment suit (Civil Case No. 3711) in 1961. The trial court, after trial and ocular inspection, ordered the defendants to vacate, a decision affirmed by the Court of Appeals in 1975 and by this Court in 1976. Meanwhile, the corporation fully paid the purchase price in 1961, and Sales Patent No. 5681 was finally issued on August 14, 1975, leading to the issuance of Original Certificate of Title.
The petitioners, some of whom were defendants in the ejectment case, sought to prohibit the execution of the ejectment judgment. They argued that the 1973 Constitution, specifically Section 11, Article XIV, which prohibits private corporations from acquiring public lands, rendered the sales award and subsequent title void. They contended the court lost jurisdiction to enforce the judgment due to this constitutional prohibition.

ISSUE

Whether Section 11, Article XIV of the 1973 Constitution, which disqualifies private corporations from purchasing public lands, applies retroactively to nullify the 1953 sales award to Biñan Development Co., Inc. and the 1975 sales patent and title, thereby divesting the trial court of jurisdiction to execute the 1964 ejectment judgment.

RULING

No. The constitutional prohibition does not have retroactive application to divest vested rights. The sales award in 1953 created a contract between the government and the corporation, granting the latter an inchoate right to a patent upon compliance with conditions. The corporation fully paid the price and complied with cultivation requirements long before the 1973 Constitution took effect. The issuance of the sales patent and title in 1975 merely confirmed a vested right that had already accrued. The Constitution is prospective; it cannot impair obligations of contracts or invalidate perfected rights. Consequently, the trial court retained jurisdiction to execute its final and executory ejectment judgment. The petition was dismissed, with the clarification that the judgment could not be enforced against petitioners who were not parties to the original ejectment case.