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Director of Lands v. Intermediate Appellate Court
Director of Lands v. Intermediate Appellate Court
146 SCRA 509 DATE: December 29, 1986 PETITIONER: The Director of Lands RESPONDENTS: Intermediate Appellate Court and Acme Plywood & Veneer Co. Inc., Etc. PONENTE: J. Narvasa FACTS: The Director of Lands appealed the judgement of the Intermediate Appellate Court which affirmed the decision of the Court of First Instance of Isabela ordering the registration in favor of Acme Plywood & Veneer Co., Inc. of five parcels of land measuring 481, 390 sqm., acquired from Mariano and Acer Infiel, members of the indigenous Dumagat Tribe and owners of the lots-in-question from time immemorial, on October 29, 1962. This was accordingly only registered on July 17, 1982 long after the aegis of the 1973 Constitution. ISSUES: 1. Whether or not the ruling in the case, Meralco v. Castro-Bartolome (114 SRC 799) should be overturned in light of jurisprudence. 2. Whether or not the conversion of the land in question is recognized. 3. Whether or not the provision barring private companies and associations from purchasing public alienable lands in 1973 Constitution is applicable retroactively. RULING: 1. HELD. In light of the jurisprudence traced from Carino v. Insular Govt, to Susi v. Razon, to Herico v. Dar, the court overturned the decision on Meralco v. Castro-Bartolome, stating that a possession is said to be prescriptively acquired by the operation of the Public Lands Act, upon conclusively presumed fulfillment of all the necessary conditions for a Government Grant. Thus, the land in question effectively ceased to be of the public domain and was therefore classified as private property at the moment of the sale through the continuous and unchallenged possession of the bona fide right to ownership from Meralcos predecessors-interest. There being no law prohibiting the sale of private lands to privately held corporations, the court thus overturned the decision. 2. HELD. Referring to the ruling in Meralco v. Castro-Bartolome, the land held by the Infiels since time immemorial was effectively deemed as private land, by the operation of the law, ipso jure. Thus, at the moment of the sale, ACME Plywood & Veneer Co., Inc., Etc. therefore, purchased
private property. There being no ruling in the 1935 Constitution prohibiting this sale, this was held to be valid. 3. NO. Acme had already obtained vested rights under the 1935 Constitution when it purchased the land from the Infiels. The provision in the 1973 Constitution prohibiting the purchase of alienable public lands by private corporations or associations cannot be retroactively applied. NOTES: