LAND TITLES: Director of Land vs. IAC and ACME Plywood & Veneer Co.

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: in favor of

Director of Lands Contention
The land is of public domain.
Corporations are prohibited by the 1973 Constitution (the Constitution in effect
that time) to lands of public domain except in lease not exceeding 1,000
hectares.

ISSUE:
Whether or not the land is already a private land Yes
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.

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

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.