GR 44237; (February, 1989) (Digest)
G.R. No. L-44237 February 28, 1989
VICTORIA ONG DE OCSIO, petitioner, vs. COURT OF APPEALS and the RELIGIOUS OF THE VIRGIN MARY, represented by M.O. Leoncia Pacquing, R.V.M., respondents.
FACTS
The case originated from cadastral proceedings in Iligan City. Petitioner Victoria Ong de Ocsio claimed ownership by purchase and possession of Lot No. 1272, asserting she and her predecessors had possessed it for many years. Private respondent Religious of the Virgin Mary, a domestic religious corporation, also claimed title to the same lot, alleging it purchased the property from the petitioner through a 1956 deed of sale and had been in possession as owner.
The Cadastral Court ruled in favor of the private respondent, finding that the evidence satisfactorily established the sale of Lot No. 1272 to the Religious of the Virgin Mary. It adjudicated the lot to the corporation, while declaring a building thereon as the petitioner’s property and ordering its removal. The Court of Appeals affirmed this decision in toto. Petitioner appealed to the Supreme Court, contesting both the factual finding of the sale and the legal capacity of the religious corporation to acquire and register the land.
ISSUE
The issues are: (1) whether the factual finding of the Cadastral Court and the Court of Appeals that petitioner sold the lot to the private respondent is binding; and (2) whether a religious corporation is disqualified from acquiring the land and having title confirmed in its name under the constitutional prohibitions and the Public Land Act.
RULING
The Supreme Court affirmed the decision of the Court of Appeals. On the factual issue, the Court upheld the uniform rule that findings of fact of the Court of Appeals are conclusive and binding on the Supreme Court, absent any of the recognized exceptions, none of which were present. Both lower courts had analyzed the evidence and found the petitioner’s version not credible, concluding the sale of the specific lot was established.
On the legal issue, the Court rejected the petitioner’s argument that the religious corporation was disqualified. Citing the 1973 and 1987 Constitution and prior rulings like Manila Electric Co. v. Castro-Bartolome, petitioner argued that only natural persons could obtain judicial confirmation of imperfect title under Section 48(b) of the Public Land Act. The Court, however, applied the current doctrine established in Director of Lands v. I.A.C.. It held that open, continuous, and exclusive possession of alienable public land for at least thirty years by a natural person ipso jure converts the land to private property. A juridical person who subsequently acquires it may have title confirmed in its name. The constitutional prohibitions do not apply to lands already converted to private ownership by natural persons under the Public Land Act. Since the petitioner and her predecessors had possessed the lot under the conditions prescribed by law prior to the sale, confirmation of title in the corporation’s name was proper. The petition was denied.