G.R. No. 54952 . March 5, 1984.
REPUBLIC OF THE PHILIPPINES (represented by the Director of Lands), Petitioner, vs. IGLESIA NI CRISTO, with its Executive Minister ERAÑO G. MANALO as CORPORATION SOLE and HON. GABRIEL O. VALLE, JR. as Presiding Judge, Court of First Instance of Ilocos Norte, Branch II, Respondents.

FACTS

On August 7, 1979, respondent Iglesia ni Cristo (INC), as a corporation sole, filed an application for original registration of a 614-square-meter parcel of land in San Pedro, Vintar, Ilocos Norte. INC claimed acquisition by deed of sale from Carmen Racimo in 1978 and asserted that its predecessors-in-interest had possessed the land for over thirty years. The Republic, through the Director of Lands, opposed the application, contending that the land remained part of the public domain and that INC, as a private corporation, was constitutionally disqualified from holding alienable lands of the public domain except by lease under Section 11, Article XIV of the 1973 Constitution. The Court of First Instance of Ilocos Norte granted the application, adjudicating the land in favor of INC, reasoning that a corporation sole was not within the constitutional prohibition and could qualify under Section 14 of the Property Registration Decree (P.D. No. 1529).

ISSUE

Whether the Iglesia ni Cristo, as a corporation sole, is qualified to apply for and acquire title to alienable lands of the public domain through judicial confirmation of imperfect title.

RULING

The Supreme Court ruled in the negative, reversing the lower court’s decision. The Court held that the constitutional prohibition in Section 11, Article XIV of the 1973 Constitution, which states that “no private corporation or association may hold alienable lands of the public domain except by lease,” applies squarely to the Iglesia ni Cristo as a corporation sole. The Court reiterated its ruling in the controlling case of Republic v. Villanueva (114 SCRA 875), which held that a corporation sole is a private corporation within the meaning of the constitutional ban. The land sought to be registered, not having been previously the subject of a successful application for confirmation of imperfect title under Section 48(b) of the Public Land Act ( Commonwealth Act No. 141 , as amended), retained its character as part of the inalienable public domain. The application, though filed under P.D. No. 1529, was essentially based on a claim of possession under a bona fide claim of ownership for at least thirty years, which is the same basis under the Public Land Act. Since the land remained public, the constitutional disqualification of private corporations from acquiring title thereto was operative. The Court rejected INC’s arguments that the land was private property acquired by prescription or that it acted merely as a trustee for its members, emphasizing that the constitutional prohibition is explicit and allows no exception for corporations sole.