The Director of Lands VS.

IAC

Facts:
Acme Plywood & Veneer Co. Inc., is a corporation duly organized in
accordance with the laws of the Philippines and duly registered with the SEC. It
ancestrally acquired five parcels of land measuring 481,390 square meter from
Mariano and Acer Infiel. The possession of the company is continuous, adverse and
public from 1926 to the time of filing and has introduced more than 45, 000, 000
worth of improvements. The Director of Lands asserts that the registration
proceedings have been commenced on July 17, 1981 or long after the 1973
Constitution had gone effect, the latter is the correctly applicable law; and since
section 11 of its Article XIV prohibits private corporations or associations from
holding alienable lands of the public domain, except by lease not to exceed 1,000
hectares (a prohibition not found in the 1935 Constitution which was in force in
1962 when Acme purchased the lands in question from the Infiels), it was reversible
error to decree registration in favor of Acme. The CFI ordered the registration in
favor of Acme which was later on affirmed by the IAC. Hence the appeal by
certiorari herein by the Director of Lands.

Issue:
W/N a corporation sole is disqualified to acquire/hold alienable lands of the
public domain, because of the constitutional prohibition qualifying only individuals
to acquire land and the provision of under the Public Land Act which applied only to
Filipino citizens or natural persons.

Ruling:
No, the correct rule is that alienable public land held by a possessor,
personally or through his predecessors-in-interest, openly, continuously and
exclusively for the prescribed statutory period (30 years under The Public Land Act,
as amended) is converted to private property by the mere lapse or completion of
said period, ipso jure. Following that rule and on the basis of the undisputed facts,
the land subject of this appeal was already private property by the time it was
acquired from the Infiels by Acme. Acme thereby acquired registrable title, there
being at the time no prohibition against said corporations holding or owning private
land. The objection that, as a juridical person, Acme is not qualified to apply for
judicial confirmation of title under The Public Land Act is technical, rather than
substantial.
While this opinion seemingly reverses an earlier ruling of comparatively
recent vintage, in a real sense, it breaks no precedent, but only reaffirms and re-
established, as it were, doctrines the soundness of which has passed the test of
searching examination and inquiry in many past cases.