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The Director of Lands vs. The Honorable Court of Appeals and Iglesia Ni Cristo G.R. No. L-56613. March 14, 1988 Facts

The Director of Lands opposed the application of Iglesia ni Cristo to register 379 square meters of land in its name. The Director argued that Iglesia did not have sufficient title, had not possessed the land for the required 30 years, and that the land was part of the public domain. However, the court ruled that Iglesia had possessed the land since 1936, completing the 30-year statutory period in 1966 and converting the land to private property by operation of law. The court also noted that private corporations were not prohibited from acquiring public land under the Constitution in force in 1966. Therefore, the land was private property and the 1973 Constitution's prohibition did not apply.

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Jefferson Dela Cruz Lasaten Jr.
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85 views2 pages

The Director of Lands vs. The Honorable Court of Appeals and Iglesia Ni Cristo G.R. No. L-56613. March 14, 1988 Facts

The Director of Lands opposed the application of Iglesia ni Cristo to register 379 square meters of land in its name. The Director argued that Iglesia did not have sufficient title, had not possessed the land for the required 30 years, and that the land was part of the public domain. However, the court ruled that Iglesia had possessed the land since 1936, completing the 30-year statutory period in 1966 and converting the land to private property by operation of law. The court also noted that private corporations were not prohibited from acquiring public land under the Constitution in force in 1966. Therefore, the land was private property and the 1973 Constitution's prohibition did not apply.

Uploaded by

Jefferson Dela Cruz Lasaten Jr.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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THE DIRECTOR OF LANDS

vs.
THE HONORABLE COURT OF APPEALS and IGLESIA NI CRISTO
G.R. No. L-56613. March 14, 1988

FACTS:

On November 28, 1973, private respondent Iglesia ni Cristo filed an application


for registration in its name of a parcel of land with an area of 379 square meters located
at Poblacion, Municipality of Amadeo, Cavite. In its application, private respondent
alleged inter alia that it was the owner in fee simple of the land afore-described, having
acquired title thereto by virtue of a Deed of Absolute Sale executed in 1947 by Aquelina
de la Cruz in its favor and that applicant. Private respondent prayed that should the
Land Registration Act not be applicable, the provisions of Chapter VIII of Commonwealth
Act No. 141, as amended by Republic Act No. 6236 be applied as applicant and its
predecessors-in-interest had been in possession of the land for more than thirty [30]
years and had introduced improvements thereon.
The Republic of the Philippines, represented by the Director of Lands, opposed
the application on the following grounds: 1] the applicant and its predecessors-in-
interest did not possess sufficient title to acquire ownership in fee simple of the parcel
of land applied for; 2] neither the applicant nor its predecessors-in-interest have been
in open, continuous, exclusive and notorious possession and occupation of the land in
question; and, 3] the subject parcel of land is a portion of the public domain not subject
to private appropriation.

ISSUES:

Whether or not the respondent is prohibited from acquiring private land as


provided under the Constitution.

RULING:

YES.

Taking the year 1936 as the reckoning point, the 30-year period of open,
continuous, exclusive and notorious possession and occupation required by law was
completed in 1966. The completion by private respondent of this statutory 30-year
period has dual significance in the light of Section 48[b] of Commonwealth Act No. 141,
as amended and prevailing jurisprudence: [1] at this point, the land in question ceased
by operation of law to be part of the public domain; and [2] private respondent could
have its title thereto confirmed through the appropriate proceedings as under the
Constitution then in force, private corporations or associations were not prohibited from
acquiring public lands, but merely prohibited from acquiring, holding or leasing such
type of land in excess of 1,024 hectares.
If in 1966, the land in question was converted ipso jure into private land, it
remained so in 1974 when the registration proceedings were commenced. This being
the case, the prohibition under the 1973 Constitution would have no application.
Otherwise construed, if in 1966, private respondent could have its title to the land
confirmed, then it had acquired a vested right thereto, which the 1973 Constitution can
neither impair nor defeat.

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