Republic of the Philippines vs Iglesia

ni Cristo (March 1984)

Business Organization Corporation Law Corporations are not Filipino
Citizens Registration of Public Lands

In 1978, Iglesia ni Cristo (INC) purchased a parcel of land from one Carmen
Racimo in Ilocos Norte. In 1979, INC sought to register said land under its
name pursuant to Section 48 (b) of the Public Land Law. The Director of
Lands opposed the application as it averred that the said parcel of land is
part of the alienable public land; that INC cannot register said land because
it is not a Filipino citizen. INC argues that it is a private land because
Racimo, its predecessor-in-interest has been in possession thereof for more
than 30 years; that the Constitutional prohibition does not apply to INC, a
corporation sole (solely incorporated by one man, Erao Manalo, a Filipino
citizen), hence it can acquire said property.

ISSUE: Whether or not INC can register said parcel of land under its name.

HELD: No.

1. The disputed land has never lost its public character. Racimo,
though occupying said land for more than 30 years, never applied for
confirmation of incomplete or imperfect title over said land. Under the
law, all lands that were not acquired from the Government either by
purchase or by grant, belong to the public domain. As exception to the
rule would be any land that should have been in the possession of an
occupant and of his predecessors-in-interest since time immemorial,
for such possession would justify the presumption that the land had
never been part of the public domain or that it had been a private
property even before the Spanish conquest.

2. Section 48 (b) of the Public Land Law allows the registration of

alienable public lands but only by Filipino citizens. INC is not a
Filipino citizen. There is no basis on the contention that as a
corporation sole, INC is not prohibited from holding said land. The
benefit only applies to Filipino citizens not to a corporation sole
which has citizenship.

NOTE: 60% rule: Corporations and Partnerships of which at least 60% of

their capital belong to Filipinos may acquire real property.