GR L 16197; (March, 1920) (Digest)
G.R. No. L-16197; March 12, 1920
CENTRAL CAPIZ, petitioner, vs. ANA RAMIREZ, respondent.
FACTS:
The petitioner, Central Capiz, entered into a contract with the respondent, Ana Ramirez, whereby the latter agreed to supply all sugar cane produced from her plantation to the petitioner for thirty years. The contract was to be converted into a right in rem and recorded as an encumbrance on the land. Before this conversion could be executed, Act No. 2874 , the Public Land Act, took effect. The respondent refused to execute the deed, contending that more than 61% of the petitioner’s capital stock was owned by persons who were not citizens of the Philippine Islands or the United States, which she believed Act No. 2874 prohibited. It is undisputed that the land in question is private agricultural land held by the respondent under a Torrens title.
ISSUE:
Whether Act No. 2874 (the Public Land Act) applies to privately owned agricultural lands, thereby prohibiting the encumbrance of such land in favor of a corporation not meeting the citizenship requirement for capital stock ownership.
RULING:
No. Act No. 2874 applies only to lands of the public domain and does not extend to privately owned agricultural lands. The Court, examining the Act’s title, specific provisions, and overall intent, held that its purpose was to regulate the disposition of public lands. Key indicators include: its short title “The Public Land Act”; Section 2 stating its provisions “shall apply to lands of the public domain”; the executive functions granted to the Director of Lands and the Secretary of Agriculture and Natural Resources, which pertain to public lands; and the provision for patents to be issued in the name of the Government. The Court further ruled that any interpretation applying the Act to private lands would violate Section 3 of the Jones Law, which requires that no bill shall embrace more than one subject, and that subject must be expressed in its title. Since the title refers to “lands of the public domain,” it cannot validly encompass private lands. Consequently, the respondent’s land, being privately owned and registered under the Torrens system, is not governed by the restrictions in Act No. 2874 . The petition was granted.