Land Titles and Deeds Case Digest: Director of Lands v. IAC (1986)

G.R. No. 73002 December 29, 1986

Lessons Applicable: Sec. 3 Art. XII, 1987 Constitution (Land Titles and Deeds)

FACTS:

• Acme Plywood & Veneer Co., Inc., a corp. represented by Mr. Rodolfo Nazario, acquired from Mariano and Acer Infiel, members of the Dumagat tribe 5 parcels of land
• possession of the Infiels over the landdates back before the Philippines was discovered by Magellan
• land sought to be registered is a private land pursuant to RA 3872 granting absolute ownership to members of the non-Christian Tribes on land occupied by them or their ancestral lands, whether with the alienable or disposable public land or within the public domain
• Acme Plywood & Veneer Co. Inc., has introduced more than P45M worth of improvements
• ownership and possession of the land sought to be registered was duly recognized by the government when the Municipal Officials of Maconacon, Isabela 
• donated part of the land as the townsite of Maconacon Isabela
• IAC affirmed CFI: in favor of 

ISSUES:

1. W/N the land is already a private land - YES
2. W/N the constitutional prohibition against their acquisition by private corporations or associations applies- NO

HELD:  IAC affirmed Acme Plywood & Veneer Co., Inc

1. YES

• already acquired, by operation of law not only a right to a grant, but a grant of the Government, for it is not necessary that a certificate of title should be issued in order that said grant may be sanctioned by the courts, an application therefore is sufficient
• it had already ceased to be of the public domain and had become private property, at least by presumption
• The application for confirmation is mere formality, the lack of which does not affect the legal sufficiency of the title as would be evidenced by the patent and the Torrens title to be issued upon the strength of said patent.
• The effect of the proof, wherever made, was not to confer title, but simply to establish it, as already conferred by the decree, if not by earlier law

    2. NO

• If it is accepted-as it must be-that the land was already private land to which the Infiels had a legally sufficient and transferable title on October 29, 1962 when Acme acquired it from said owners, it must also be conceded that Acme had a perfect right to make such acquisition
• The only limitation then extant was that corporations could not acquire, hold or lease public agricultural lands in excess of 1,024 hectares