Republic v. Gonong
REITERATIONFacts
The Antecedents: The Iglesia ni Cristo (Iglesia), a corporation sole represented by its Executive Minister Erano G. Manalo, filed an application for registration of a parcel of land with an area of 922 square meters in Ilocos Norte. The land was acquired by the Iglesia on July 20, 1953, from Gregorio Gamet, who allegedly possessed it for over thirty years. The lot was declared for realty tax purposes in 1954, and taxes have been paid thereon since then. A chapel of the Iglesia stands on the land. Procedural History: The Republic of the Philippines, through the Director of Lands, opposed the application, arguing that the Iglesia, as a private corporation, is disqualified from holding alienable public lands and that the applicant and its predecessor-in-interest had not possessed the land openly, continuously, exclusively, and notoriously since June 12, 1945, or prior thereto. The Land Registration Court granted the Iglesia's application, finding sufficient evidence of ownership and possession, and dismissed the government's opposition. The Republic's motion for reconsideration was denied. The Petition: The Republic filed a petition for certiorari, stressing the Iglesia's disqualification to hold lands of the public domain except by lease, pursuant to Section 11, Article XIV of the 1973 Constitution. The Iglesia argued that as a corporation sole, it is a mere administrator and not the owner, and that the property is private, not alienable public land.
Issue(s)
Whether the Iglesia ni Cristo, as a corporation sole, is disqualified from holding alienable lands of the public domain. Whether the land in question is alienable public land or private property.
Ruling
The Supreme Court set aside the decision of the respondent Judge and dismissed the application for registration of the Iglesia ni Cristo. No costs were awarded.
Ratio Decidendi
On the disqualification of the Iglesia ni Cristo: The Court held that the Iglesia ni Cristo, as a corporation sole or a juridical person, is disqualified from acquiring or holding alienable lands of the public domain. This disqualification stems from the constitutional prohibition found in Section 11, Article XIV of the 1973 Constitution, which states that no private corporation or association may hold alienable lands of the public domain except by lease not exceeding one thousand hectares. The Court reiterated its ruling in Republic of the Philippines vs. Judge Candido P. Villanueva, 114 SCRA 875 (June 29, 1982), which is squarely on point with the present case. The Iglesia's argument that a corporation sole is merely an administrator and not an owner was not given weight in the context of holding public lands. Furthermore, the Court emphasized that the Iglesia is not entitled to the benefits of Section 48(b) of the Public Land Law, as this provision applies only to Filipino citizens or natural persons. A corporation sole, lacking nationality, cannot avail itself of such provisions. On the nature of the property: The Court categorically pronounced that the land in question is public land, not private property. It distinguished the present case from Susi vs. Razon and Director of Lands, 48 Phil. 424, where the land was considered private due to possession since time immemorial. The lots sought to be registered in this case do not fall within that category and are still considered public lands. A land registration proceeding under Section 48(b) presupposes that the land is public, as held in Mindanao vs. Director of Lands, L-19535 (July 10, 1967). The Court cited Oh Cho vs. Director of Lands, 75 Phil. 890, stating that all lands not acquired from the Government by purchase or grant belong to the public domain, unless possessed since time immemorial. The right of an occupant under Section 48(b) is merely an 'inchoate title' and the land still pertains to the State before the issuance of a certificate of title, as noted in Uy Un vs. Perez, 71 Phil. 508.
Main Doctrine
A corporation sole, being a juridical person, is disqualified from acquiring or holding alienable lands of the public domain under Section 11, Article XIV of the 1973 Constitution, and cannot avail itself of the benefits of Section 48(b) of the Public Land Law, which is applicable only to Filipino citizens or natural persons.