G.R. No. L-61145, February 20, 1984
Republic of the Philippines (Director of Lands), Petitioner, vs. Iglesia ni Cristo and Judge Domingo M. Angeles, Branch I, Court of First Instance of Camarines Norte, Respondents.

FACTS

The Iglesia ni Cristo (INC), a registered corporation sole, filed an application for confirmation and registration of title over two parcels of land in Camarines Norte, used as chapel sites. The INC traced its ownership through purchases from previous owners, who allegedly possessed the lots since 1920. The application was based on Section 48(b) of the Public Land Law (Commonwealth Act No. 141), claiming that the INC and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession for over thirty years. The Director of Lands opposed the application.
The trial court granted the INC’s application and ordered the lands registered in its name as a corporation sole. The Republic appealed, arguing that the same legal issue had already been definitively resolved against the INC in a series of prior Supreme Court decisions.

ISSUE

Whether the Iglesia ni Cristo, as a corporation sole, is entitled to confirmation and registration of title over the subject lands under the Public Land Law.

RULING

The Supreme Court reversed the trial court’s decision and dismissed the INC’s application. The ruling was grounded on two principal legal barriers, which were already settled law under the doctrine of stare decisis.
First, the Court held that Section 48(b) of the Public Land Law expressly confers the right to apply for confirmation of imperfect title only upon “citizens of the Philippines.” A corporation sole, such as the INC, is a juridical person distinct from its members and is not a Filipino citizen. Therefore, it is statutorily disqualified from availing itself of this mode of acquiring title.
Second, the Court cited Section 11, Article XIV of the 1973 Constitution, which prohibited private corporations from holding alienable lands of the public domain except by lease. The lands subject of the application remained public lands until their title was perfected. As a corporation, the INC was constitutionally barred from acquiring ownership of such lands. The Court rejected the INC’s alternative argument that it could register the lands as a trustee, noting that its application was filed explicitly as a corporation sole and not in a fiduciary capacity. Consequently, the matter was deemed res judicata, being governed by prior jurisprudence which had uniformly ruled against the INC’s capacity to register public lands under these provisions.