Republic v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Respondent Circulo Bantayano Foundation, Inc. applied for the registration of a parcel of land located in Poblacion Bantayan, Cebu, with an area of 108,711 square meters. The Foundation claimed ownership in fee simple or through a possessory information title, asserting it purchased the land on December 5, 1974, from the heirs of the late Pedro Escario, Sr. They further alleged that the land, assessed for taxation purposes at P17,850.00 in 1978, had been occupied and possessed openly, continuously, notoriously, and peacefully by the applicant and its predecessors-in-interest for over 40 years. The petitioner, Republic of the Philippines, opposed the application, contending that the respondent lacked title and was disqualified as a corporation from owning public domain lands under the 1973 Constitution. 2. Procedural History: The application for land registration was initially filed before the Court of First Instance of Cebu. The petitioner opposed the application but failed to present any evidence during the trial. The trial court, finding the applicant's possession to be peaceful, open, public, continuous, notorious, and in the concept of absolute owner for over thirty years, including that of its predecessors-in-interest, and noting the applicant's regular payment of taxes, rendered a decision declaring Circulo Bantayano Foundation, Inc. as the owner and ordering the issuance of a decree of registration. The petitioner appealed this decision to the Court of Appeals, which affirmed the trial court's ruling. The Court of Appeals reasoned that the application was for the confirmation of an imperfect title acquired through long possession, not for a grant of public domain land, and highlighted the petitioner's failure to present evidence to the contrary. 3. The Petition: The petitioner, Republic of the Philippines, seeks review of the Court of Appeals' decision affirming the trial court's grant of land registration to Circulo Bantayano Foundation, Inc. The core issue presented to the Supreme Court is whether the respondent corporation is qualified under the 1973 or 1987 Constitutions to acquire and register the disputed lot. The petitioner argues that a private corporation is disqualified from owning lands of the public domain. The Supreme Court, however, denied the petition, finding that the land, at the time of its acquisition by the corporation in 1974, was no longer part of the public domain due to long years of exclusive, continuous, and adverse possession by its predecessors-in-interest, thereby conferring ownership ipso jure upon them and enabling them to convey title to the corporation. The Court found that the prohibitions in the 1973 and 1987 Constitutions were inapplicable in this instance.
Issue(s)
Whether the respondent corporation is disqualified under the 1973 or 1987 Constitution to acquire and register the disputed lot. Whether the parcel of land applied for is a portion of the public domain not subject to private appropriation. Whether the applicant and its predecessors-in-interest have been in peaceful, open, public, continuous, notorious possession in the concept of owner of the land sought to be registered for more than thirty (30) years. Whether the applicant's application for registration should have been dismissed and the land declared part of the public domain.
Ruling
The petition is denied for lack of merit, and the assailed decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the disqualification of the corporation to acquire lands of the public domain: The Court reiterated the constitutional prohibition under both the 1973 and 1987 Constitutions that a private corporation cannot acquire lands of the public domain. However, the Court clarified that this prohibition applies only to lands that are, at the time of acquisition, still part of the public domain. In this case, the land was acquired by the corporation in 1974. The Court found that long years of exclusive, continuous, and adverse possession by the applicant's predecessors-in-interest had already converted the land into private property ipso jure prior to its acquisition by the corporation. Therefore, at the time of the corporation's purchase, the land was no longer public land, and the constitutional prohibition did not apply. On whether the land is part of the public domain not subject to private appropriation: The Court affirmed the findings of the lower courts that the applicant and its predecessors-in-interest had been in possession of the land for more than thirty years. This prolonged possession, characterized as peaceful, open, public, continuous, and notorious, in the concept of owners, established the land as private property. The petitioner's failure to present any evidence to controvert this claim further supported the conclusion that the land was not part of the public domain subject to private appropriation. On the sufficiency of possession for over thirty years: The Court upheld the findings of the Court of Appeals and the trial court that the applicant's predecessors-in-interest had possessed the property for at least three generations or for more than 30 years immediately preceding the filing of the application for confirmation of title. This extensive period of possession, coupled with the applicant's subsequent acquisition and continued possession, satisfied the requirements for establishing ownership and confirming an imperfect title. On the dismissal of the application and declaration of land as public domain: Based on the established facts and legal principles, the Court found no error in the lower courts' decisions to grant the application for registration. The evidence presented by the applicant sufficiently proved their ownership and the private character of the land, thereby negating the petitioner's claim that it was part of the public domain. The petitioner's failure to present any evidence to support its opposition was a critical factor in the dismissal of its arguments.
Main Doctrine
A private corporation, even if domestic, cannot acquire lands of the public domain. However, if prior to the acquisition by the corporation, the land was already private land due to long years of exclusive, continuous, and adverse possession by its predecessors-in-interest, the constitutional prohibition does not apply.