G.R. No. 88233 . October 4, 1991.
OSCAR NATIVIDAD, BARTOLOME RAMOS and EUGENIO PASCUAL, petitioners, vs. THE COURT OF APPEALS and REPUBLIC OF THE PHILIPPINES.

FACTS

Tomas Claudio Memorial College, Inc. (TCMC), a private corporation, filed an application for original registration of six parcels of land in Morong, Rizal. The Director of Lands opposed, arguing TCMC was a corporation disqualified from holding alienable lands of the public domain under the 1973 Constitution. During the pendency of the case, TCMC sold the lots to the individual petitioners—Oscar Natividad, Eugenio Pascual, and Bartolome Ramos. The trial court granted TCMC’s motion to substitute the petitioners as applicants.
The petitioners presented evidence that their predecessors-in-interest, from whom TCMC had purchased the lots, had been in open, continuous, exclusive, and notorious possession of the lands for over thirty years, dating back to periods well before World War II. The Regional Trial Court granted the application for registration. The Court of Appeals reversed, ruling that since TCMC, a corporation, was the original applicant, the constitutional prohibition applied and the land remained part of the public domain, incapable of registration.

ISSUE

Whether the constitutional prohibition against corporations acquiring alienable lands of the public domain bars the registration of titles by the petitioners, who are natural persons, where the land was originally applied for by a corporation that purchased it from individuals who had possessed it for the requisite period.

RULING

The Supreme Court granted the petition and reinstated the trial court’s decision. The legal logic centers on the nature of the land at the time of its acquisition by TCMC. The Court held that open, continuous, exclusive, and notorious possession of alienable public land for the period prescribed by law (since June 12, 1945, or earlier) operates as an express grant from the State, converting the land into private property by operation of law through acquisitive prescription.
Consequently, when TCMC purchased the lots in 1979, the lands were already private, having been converted by the prescriptive possession of its predecessors-in-interest. The constitutional prohibition (Article XIV, Section 11 of the 1973 Constitution) applies only to alienable lands of the public domain; it does not extend to private lands. Therefore, TCMC’s purchase was of private property, not a constitutionally barred acquisition of public land. The subsequent substitution by the individual petitioners was permissible, and the technical defect of the initial corporate application did not defeat the vested ownership rights already acquired through prescription by the original possessors. The confirmation proceeding merely recognizes this pre-existing title.