G.R. No. L-73002 December 29, 1986
THE DIRECTOR OF LANDS, petitioner, vs. INTERMEDIATE APPELLATE COURT and ACME PLYWOOD & VENEER CO., INC., respondents.

FACTS

Acme Plywood & Veneer Co., Inc. sought judicial confirmation of title over five parcels of land in Isabela, acquired in 1962 from Mariano and Acer Infiel, members of the Dumagat cultural minority. The trial court found that the Infiels and their ancestors had possessed the lands since time immemorial, satisfying the required period of open, continuous, exclusive, and notorious possession under Section 48 of the Public Land Act. The court ordered registration in favor of Acme, a decision affirmed by the Intermediate Appellate Court. The Director of Lands appealed, conceding the Infiels’ qualification for confirmation but contesting Acme’s eligibility under the 1973 Constitution, which prohibits private corporations from holding alienable lands of the public domain except by lease. The registration application was filed in 1981, after the 1973 Constitution took effect.

ISSUE

Whether the constitutional prohibition against private corporations holding alienable lands of the public domain under the 1973 Constitution bars the registration of title in favor of Acme, which acquired the land from qualified cultural minority members in 1962 under the regime of the 1935 Constitution.

RULING

The Supreme Court ruled in favor of Acme and affirmed the registration. The legal logic hinges on the nature of the land and the vested right acquired by Acme. The Court held that the land, by virtue of the Infiels’ possession since time immemorial, had ceased to be part of the public domain and was already private land at the time of sale in 1962. This conclusion is supported by Republic Act No. 3872, which grants absolute ownership to cultural minorities over their ancestral lands. Consequently, Acme acquired a private land, and the transaction was governed by the 1935 Constitution, which contained no prohibition against corporate ownership. The 1973 Constitution’s prohibition applies only to alienable lands of the public domain, not to lands already privatized. The Court emphasized that the Infiels had a vested right to a government grant, which they could legally transfer. To require the Infiels to file the application themselves would be a mere formality, as the right had already been earned and transferred. Thus, Acme, as a successor-in-interest, could seek confirmation of that perfected right. The constitutional prohibition was not intended to invalidate vested rights acquired under a previous constitutional regime.