GR L 58077; (January, 1986) (Digest)
G.R. No. L-58077, January 7, 1986
THE DIRECTOR OF LANDS, petitioner, vs. HERMANOS Y HERMANAS DE STA. CRUZ DE MAYO, INC., and JUDGE JESUS M. ELBINIAS, Court of First Instance of Bulacan, Sta. Maria Branch, respondents.
FACTS
The respondent corporation, Hermanos y Hermanas de Sta. Cruz de Mayo, Inc., filed an application for registration of a 281-square meter residential lot in San Jose del Monte, Bulacan. The corporation acquired the land in 1976 by purchase from the heirs of Macario Zalamea. The property’s chain of possession traced back to Alejandra Santiago-Zalamea, who allegedly possessed it since 1900. The corporation erected a chapel on the land.
The trial court granted the application for registration. The Director of Lands appealed, arguing that a corporation is constitutionally and statutorily disqualified from holding alienable lands of the public domain, except by lease, and thus cannot avail itself of judicial confirmation of imperfect title.
ISSUE
Whether a private corporation can apply for judicial confirmation of title over alienable lands of the public domain under the Public Land Act.
RULING
The Supreme Court reversed the trial court and dismissed the application. The ruling is anchored on two primary legal grounds. First, Section 11, Article XIV of the 1973 Constitution explicitly provides that “no private corporation or association may hold alienable lands of the public domain except by lease.” A land registration proceeding presupposes the land is part of the public domain, and this constitutional prohibition squarely applies to the respondent corporation.
Second, the provisions for judicial confirmation of imperfect title under Section 48(b) of the Public Land Act ( Commonwealth Act No. 141 ) are available only to natural persons, not to juridical entities. The law expressly confers the right to apply upon “citizens of the Philippines,” which has been consistently interpreted to refer to individuals. Section 49 of the same Act reinforces this by stating that persons not possessing the qualifications in the preceding section cannot apply for its benefits.
The Court held that the land remained part of the public domain until its registration. The prior possession by the corporation’s predecessors-in-interest, who were private individuals, did not convert the land into private property before a grant of title. Consequently, the corporation, as a juridical person, was absolutely barred from initiating the registration proceeding. The matter was deemed res judicata, having been settled in a line of prior cases involving similar corporate applicants. The application was dismissed for lack of legal capacity of the applicant.