DIRECTOR OF LANDS V IAC ● “The application for confirmation is mere formality, the lack of which
J. Narvasa | GR No. 73002, Dec 29, 1986 does not affect the legal sufficiency of the title as would be
Facts:
● This case started when ACME Plywood, sought to register 5
parcels of land. The Director of Land opposes the registration.
● 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 land dates 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.
● IAC affirmed CFI and ruled in favor of ACME
● Director of Land’s Contention
○ The land is of public domain.
○ Corporations are prohibited by the 1973 Constitution (the
Constitution in effect that time) to hold lands of public
domain except in lease not exceeding 1,000 hectares.
Issues:
1. Whether or not the land is already a private land -> Yes
2. Whether or not the constitutional prohibition against acquisition by
private corporations or associations applies -> No
Ruling:
Whether or not the land is already a private land?
● The land is already private land not only in right to a grant but by
operation of law.
● The SC further said that for the grant to be honored by the court, it
is not necessary that they have a certificate of title, an application
for registration is sufficient for the grant to be honored.
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”
Whether or not the constitutional prohibition against their acquisition by
private corporations or associations applies?
● The SC held in this case that the constitutional prohibition does not
apply because the land was already a private land to which the
Infiels, who are members of the Dumagat Tribe, have a legal,
sufficient and transferrable title over the land on October 29, 1962
when ACME acquired it from them.
● Since the land acquired by the private corporation is a private land
to begin with then ACME has a perfect right to make such
acquisition.
● The only limitation imposed to the corporations when the
acquisition was made was that they could not hold or lease public
agricultural lands in excess of 1,0124 hectares.
● The SC said that there is no need to dwell on the 1935 or the 1973
Constitution as contended by the Director of Land because the land
is already converted to private land. And there is no prohibition
whether in the 1935 or 1973 Constitution on the acquisition of
private corporations over private lands. The 1973 Constitution and
the present 1987 Constitution only gives a prohibition on private
corporations in their acquiring lands of the public domain, meaning
your agricultural lands.
● Now the INFIELS in the evidence that was presented by Acme
proved that the INFIELS were already in possession since time
immemorial, even before Magellan discovered the Philippines. So
even before the Spaniards discovered the Philippines, it was
already private property. So if the land has already been converted
to private land, then the private corporation may own that land
because there is no prohibition on the acquisition of a private
corporation on private lands.