G.R. No. L-56025 November 25, 1982
Republic of the Philippines, petitioner, vs. The Honorable Arsenio M. Gonong and Iglesia ni Cristo, respondents.

FACTS

Respondent Iglesia ni Cristo (INC), a corporation sole, filed an application for original registration of a 922-square-meter parcel of land in Ilocos Norte under Section 48(b) of the Public Land Act. INC alleged it acquired the land in 1953 from Gregorio Gamet, who had possessed it for over thirty years, and had since paid realty taxes and constructed a chapel on the lot. The Republic, through the Director of Lands, opposed the application on two primary grounds: that INC, as a private corporation, is constitutionally disqualified from holding alienable lands of the public domain, and that neither INC nor its predecessor had possessed the land since June 12, 1945.
The Land Registration Court granted INC’s application, finding its evidence of ownership and possession sufficient. The Republic’s motion for reconsideration, based solely on the constitutional disqualification of a private corporation, was denied. The Republic thus elevated the case via certiorari.

ISSUE

Whether the Iglesia ni Cristo, as a corporation sole, is disqualified from applying for judicial confirmation of imperfect title over alienable public land.

RULING

The Supreme Court ruled in favor of the Republic and set aside the lower court’s decision, dismissing INC’s application for registration. The Court’s ruling was anchored on two key points established in the controlling precedent of Republic vs. Villanueva.
First, the land subject of the application remains public land. The Court clarified that a proceeding under Section 48(b) of the Public Land Act inherently presupposes the land is part of the public domain. The exception for land considered private property—possession since time immemorial—did not apply here. Until a certificate of title is issued, the occupant holds only an inchoate right, and the land pertains to the State.
Second, INC, as a corporation sole or juridical person, is disqualified from acquiring or holding alienable lands of the public domain by direct constitutional prohibition. Section 11, Article XIV of the 1973 Constitution explicitly bars private corporations from holding such lands except by lease. The benefits of Section 48(b), which grants the right to apply for confirmation of title, are reserved exclusively for Filipino citizens or natural persons. A corporation sole, having no nationality, cannot avail itself of this right. Therefore, INC’s constitutional disability was fatal to its application for registration.