G.R. No.

L-49623 June 29, 1982

MANILA ELECTRIC COMPANY,
vs.
JUDGE FLORENLIANA CASTRO-BARTOLOME of the Court of First Instance of Rizal, Makati
Branch XV, and REPUBLIC OF THE PHILIPPINES,

Facts:
The Manila Electric Company purchased two lots (165 sqm.) at Tanay, Rizal on August13, 1976
from Piguing spouses. After acquisition, they subsequently filed for judicial confirmation of
imperfect title on Dec. 1, 1976. However, the court denied the petition and the corresponding
appeal was likewise rejected. It elevates its appeal with the following arguments;
firstly, the land in question had essentially been converted to private land by virtue of
acquisitive prescription as a result of open continuous and notorious possession and
occupation for more than thirty years by the original owner, Olimpia Ramos and
his predecessor in interest, Piguingspouses, whom Meralcoa c q u i r e d t h e d i s p u t e d
land, and finally, the substantial rights acquired by Ramos spouses and
Peguing spouses for judicial confirmation of imperfect title, extend to Meralco by virtue of
the provision of the Public Land Law.

Issue:
1.Whether or not Meralco as a juridical person, allowed under the law to hold lands of public domain
and apply for judicial confirmation of imperfect title.2.Does the possession tacked to predecessor
Private Corporation automatically guarantee its rights to possession and title of the land.3.Whether or
not it is contingent for a judicial confirmation of title before any grant would be extended to a juridical
person.

Held:
1.No. Private corporation or juridical person is prohibited and not allowed under the law to hold
land of public domain. Article XIV Sec. 14 of the 1973 Constitution prohibits private corporations
from holding alienable lands of the public domain except for lease of lands not exceeding one thousand
hectares.

2.No. The presumption that since they bought the property from the person who
occupied the land in open, continuous and notorious possession of the public land for more than
thirty years, does not automatically amount to rights and possession. It would cease to be
public only upon the issuance of the
certificateo f t i t l e t o a n y F i l i p i n o c i t i z e n c l a i m i n g i t u n d e r t h e l a w . T h i s c o n c l u s i
on isanchored on the principle that
" a l l l a n d s t h a t w e r e n o t a c q u i r e d f r o m t h e Government, either by purchase
or by grant, belong to the public domain. The exception to the rule is only when the
occupant and his predecessors-in-interes