Director of Lands v. Manila Electric Company
REITERATIONFacts
The Antecedents: Manila Electric Company (Meralco) filed an amended application for registration of a parcel of land located in Taguig, Metro Manila. Meralco acquired the land by purchase from Ricardo Natividad, who in turn acquired it from his father, Gregorio Natividad. Meralco's predecessors-in-interest had possessed the property under the concept of owner for more than 30 years. The property was declared for taxation purposes under Meralco's name, and taxes were paid. Procedural History: The respondent Judge ordered the registration of the property in the name of Meralco. The Director of Lands interposed a petition, raising the issue of whether a corporation may apply for registration of title to land. The Petition: The Director of Lands filed a petition for certiorari, questioning the decision of the respondent Judge.
Issue(s)
Whether a corporation may apply for registration of title to land. Whether open, exclusive, and undisputed possession of alienable public land for the period prescribed by law creates a legal fiction whereby the land ceases to be public land and becomes private property.
Ruling
The petition is DENIED. The questioned decision of the respondent Judge is AFFIRMED.
Ratio Decidendi
On the issue of whether a corporation may apply for registration of title to land: The Court reiterated its ruling in two recent cases, The Director of Lands v. Intermediate Appellate Court and Acme Plywood & Veneer Co., Inc. and The Director of Lands v. Hon. Bengzon and Dynamarine Corporation, which affirmed that a corporation may indeed apply for registration of title. The fact that the confirmation proceedings were instituted by a corporation was considered an accidental circumstance, productive of a defect hardly more than procedural and in nowise affecting the substance and merits of the right of ownership sought to be confirmed. To deny Meralco the right to register its property, which was validly acquired, would be a rigid subservience to the letter of the law, ignoring the substance of the right. On the issue of whether open, exclusive, and undisputed possession of alienable public land for the period prescribed by law creates a legal fiction whereby the land ceases to be public land and becomes private property: The Court upheld the doctrine established in Acme Plywood & Veneer Co., Inc. that such possession creates the legal fiction whereby the land, upon completion of the requisite period, ipso jure ceases to be public land and becomes private property, without the need of judicial or other sanction. The statute provides that possessors shall be conclusively presumed to have performed all conditions essential to a Government grant and shall be entitled to a certificate of title. Confirmation proceedings are thus merely a formality to ascertain the character and length of possession, and registration recognizes a title already vested, not one that is conferred by registration.
Main Doctrine
A corporation may apply for registration of title to land, and open, exclusive, and undisputed possession of alienable public land for the period prescribed by law creates the legal fiction whereby the land ceases to be public land and becomes private property, entitling the possessor to a certificate of title.