Superior General v. Republic
REITERATIONFacts
The Antecedents: The Religious of the Virgin Mary (RVM), a religious congregation, filed an application for registration of a 4,539-square meter parcel of land in Borongan, Eastern Samar, alleging acquisition through a series of sales and donation from five individuals and continuous possession under a bona fide claim of ownership for over thirty years. The RVM sought registration under the Property Registration Decree (PRD) or the Public Land Act (PLA). Procedural History: The Republic opposed the application, asserting that the RVM and its predecessors-in-interest had not possessed the land openly, continuously, exclusively, and notoriously since June 12, 1945, that the deeds and tax declarations were insufficient proof, that the RVM could not claim based on Spanish titles, and that the parcel was part of the public domain. The Regional Trial Court (RTC) granted the RVM's application, finding proof of ownership since 1946. The Court of Appeals (CA) reversed the RTC decision, ruling that the RVM failed to establish the provenance and duration of its predecessors' titles, and that its possession could not be counted for acquiring title to public land due to constitutional prohibitions against private corporations holding such lands. The CA noted that the 30-year possession rule under R.A. 1942 was repealed by P.D. 1073, which pegged the reckoning point to June 12, 1945, and that possession under Section 14(2) of the PRD applies only to private lands. The Petition: The RVM filed a petition for review on certiorari, arguing that the parcel had become private property before the constitutional ban on corporate land ownership took effect, and that as a religious corporation composed of Filipino citizens, it should be entitled to acquire lands of the public domain. The Republic reiterated the CA's reasoning, asserting that religious corporations are included in the constitutional prohibition.
Issue(s)
Whether the RVM was able to prove the requisite possession under the Public Land Act, as amended. Whether the claimed parcel is alienable and disposable. If the claimed parcel is alienable and disposable land of the public domain, whether the RVM may acquire ownership thereof.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals' decision, and remanded the case to the Court of Appeals with directions to order a resurvey of the parcel, receive evidence on its land classification status and the possession of the RVM's predecessors-in-interest, and resolve the case thereafter.
Ratio Decidendi
On the requisite possession under the Public Land Act, as amended: The Court acknowledged that R.A. No. 11573, which amended the PLA and PRD, applies retroactively to pending applications. Under the amended law, possession for at least twenty (20) years is required. While the RVM acquired portions of the land at different times between 1946 and 1953, the Court noted that the 1973 Constitution disqualified private corporations from holding alienable public domain lands starting January 17, 1973. The Court found that the RVM's own possession might have met the twenty-year requirement for most portions before this cut-off date, but the possession of the portion acquired on July 6, 1953, might not have. Therefore, the Court deemed it necessary to allow the RVM to present evidence on the nature and circumstances of its predecessors-in-interest's possession, particularly concerning the portion acquired from Cada, to determine if the twenty-year period was met prior to the constitutional ban by tacking possession. On the land classification status of the claimed parcel: The Court found that the Certification issued by the Community Environment and Natural Resources Office (CENRO) of Borongan, stating the parcel is within the alienable and disposable portion of the public domain, is not sufficient proof on its own, as per Dumo v. Republic. While R.A. No. 11573, Section 7, now deems sufficient a certification by a DENR-designated geodetic engineer imprinted on the survey plan, this certification must be based on applicable administrative orders or land classification maps. Given the insufficiency of the evidence on record, the Court remanded the case to the CA for the reception of additional evidence on the land classification status, requiring proof of declaration as alienable and disposable through an applicable Forestry Administrative Order, DENR Administrative Order, Executive Order, Proclamation, or land classification map at the time of the application. On the qualification of the RVM to hold alienable lands of the public domain: The Court reiterated the constitutional prohibition found in Article XII, Section 3 of the 1987 Constitution, which disqualifies private corporations, including religious corporations, from holding alienable lands of the public domain except by lease. The Court emphasized that this prohibition applies to all private corporations, regardless of their nature (stock, non-stock, religious, etc.), to prevent the accumulation of vast landholdings and circumventing individual acquisition limits. The Court rejected the RVM's argument that the prohibition infringes upon the rights to equal protection and religious freedom, holding that the Constitution must be harmonized and that land tenure is not indispensable to the free exercise of religion. The Court clarified that while the RVM itself cannot acquire alienable public land, possession that meets statutory requirements can convert public land into private land by operation of law, which the RVM could then acquire. The Court also distinguished the case from Roman Catholic Apostolic Administrator of Davao, Inc. v. Land Registration Commission, where the land involved was private land.
Main Doctrine
The Supreme Court remanded the case for reception of additional evidence regarding the land classification status and the nature of possession by predecessors-in-interest, applying the retroactive provisions of R.A. No. 11573, and reiterated that religious corporations, like other private corporations, are disqualified from holding alienable lands of the public domain except by lease, but possession that meets statutory requirements can convert public land to private land, thereby allowing acquisition.