G.R. No. 91189 November 27, 1992
THE DIRECTOR OF LANDS, petitioner, vs. SAMUEL BUYCO and EDGAR BUYCO, represented by their attorney-in-fact, RIEVEN H. BUYCO and THE COURT OF APPEALS, respondents.

FACTS

On 14 October 1967, Samuel and Edgar Buyco, both naturalized American citizens (on 12 September 1975 and 29 January 1972, respectively), filed an application for registration of a 3,194,788-square-meter parcel of land in Odiongan, Romblon, claiming ownership by inheritance and donation. The land was originally owned by their grandfather, Charles Hankins, an American who died in 1937. Through a Project of Partition dated 25 June 1947 in Special Proceedings No. 796, the estate, including the subject land, was divided among Hankins’ heirs, including the applicants’ mother, Lilia Hankins. Subsequent transactions (partition of Laura Hankins’ share, a sale by William Hankins to Marcelino Buyco, a donation from Marcelino Buyco to his children, and a partition among the Buyco brothers) led to the applicants acquiring the property. The Regional Trial Court granted the application for registration on 5 February 1985. The Director of Lands appealed to the Court of Appeals, arguing that the applicants, as American citizens, are constitutionally disqualified from acquiring land, that they failed to prove proprietary rights acquired before naturalization, and that they did not overcome the presumption that the land is public domain. The Court of Appeals dismissed the appeal on 21 November 1989. The Director of Lands then filed this petition for review.

ISSUE

1. Whether the private respondents, as American citizens, are barred by the Constitution from applying for registration of land.
2. Whether the private respondents had established proprietary rights over the land before acquiring American citizenship.
3. Whether the private respondents successfully overthrew the presumption that the land is public land.

RULING

1. No. The constitutional prohibition against aliens acquiring lands of the public domain applies only to the acquisition of title to public land by purchase or grant from the government, not to the confirmation of an imperfect title already acquired by prescription. Since the private respondents’ claim is based on a right of private ownership alleged to have been vested in them or their predecessors-in-interest before they became American citizens, their alienage does not bar confirmation of that title.
2. Yes. The private respondents, who were Filipino citizens at the time they inherited the land from their Filipino mother, Lilia Hankins, acquired a vested right to the property. This right was not lost upon their subsequent naturalization as American citizens. The evidence, including the Project of Partition, deeds, tax declarations, and tax payments, established that they and their predecessors-in-interest had possessed the land openly, continuously, exclusively, and notoriously under a claim of ownership since before 12 June 1945, thereby acquiring an imperfect title subject to confirmation.
3. Yes. The private respondents presented sufficient evidence to overcome the presumption that the land is public domain. Their predecessors-in-interest had possessed the land in the concept of an owner for over eighty years. The land was declared for taxation purposes, real estate taxes were paid, and the survey plan was approved. The possession and occupation constituted an exception to the general rule, as the land was already converted to private property by operation of law prior to the application for confirmation. The application was properly filed under Section 48(b) of the Public Land Act, as amended.