Ong de Ocsio v. Court of Appeals
REITERATIONFacts
The Antecedents: The case originated from cadastral proceedings for the settlement and adjudication of title to a large tract of land in Iligan City. Victoria Ong de Ocsio (petitioner) claimed ownership of Lot No. 1272 (256 sq. meters) and Lot No. 1273 (21 sq. meters), alleging ownership by purchase and possession for fifteen years, with predecessors-in-interest possessing for sixty years. Procedural History: The Religious of the Virgin Mary (private respondent) claimed ownership of the same lots, averring they bought them from Victoria Ong de Ocsio and had been in possession as owner for over four years, with prior possession by predecessors being immemorial. The Cadastral Court found that Victoria Ong de Ocsio had sold Lot No. 1272 to the Religious of the Virgin Mary via a deed of sale dated April 12, 1956, and Lot No. 1273 was a road right of way granted to the City of Iligan. The court adjudicated Lot No. 1272 to the Religious of the Virgin Mary, declared the building on the lot as property of Victoria Ong de Ocsio, ordered its removal within 90 days, and dismissed Victoria Ong de Ocsio's claim to the lot. The Court of Appeals affirmed this decision in toto. The Petition: Victoria Ong de Ocsio appealed to the Supreme Court, questioning the factual determination that she sold the lot to the private respondent and the legal conclusion that the Religious of the Virgin Mary, a corporation, was not disqualified from acquiring the land under the 1973 and 1987 Constitutions.
Issue(s)
Whether the Court of Appeals erred in its factual determination that petitioner sold Lot No. 1272 to the private respondent. Whether the Religious of the Virgin Mary, a religious corporation, is disqualified from acquiring and registering Lot No. 1272 under the 1973 and 1987 Constitutions.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals in toto, upholding the sale of Lot No. 1272 to the Religious of the Virgin Mary and its right to have title confirmed in its name.
Ratio Decidendi
On the factual determination of the sale: The Court reiterated the time-honored rule that findings of fact of the Court of Appeals are generally final and conclusive on the Supreme Court, subject only to specific exceptions not present in this case. Both the Cadastral Court and the Court of Appeals, after weighing the testimonial and documentary evidence, concluded that petitioner's version of the facts was untrue and that Lot No. 1272 was indeed the subject of the sale and had been transferred to the Religious of the Virgin Mary. Therefore, the factual finding of the sale was upheld. On the disqualification of the religious corporation: The Court clarified that while previous rulings (citing Manila Electric Co. v. Castro-Bartolome and Republic v. Villanueva) suggested that corporations might be disqualified from judicial confirmation of imperfect title under Section 48(b) of the Public Land Act, current doctrine has evolved. The Court en banc, in Director of Lands v. I.A.C., established that open, continuous, and exclusive possession of alienable public land for at least thirty (30) years ipso jure converts the land to private property. A juridical person who thereafter acquires such land may have title confirmed in its name. The Court emphasized that the prohibition in the 1973 and 1987 Constitutions against acquisition or registration of lands by private corporations does not apply to public lands already converted to private ownership by natural persons under the Public Land Act. Since petitioner and her predecessors-in-interest possessed Lot No. 1272 for the period and under the conditions prescribed by law for acquiring ownership of disposable public land prior to its sale to the Religious of the Virgin Mary, confirmation of title in the latter's name was entirely in order.
Main Doctrine
A juridical person may have title to alienable public land confirmed in its name if it acquired the land from natural persons who had possessed and occupied it openly, continuously, and exclusively for at least thirty (30) years, thereby converting the land to private property prior to the acquisition by the juridical person.