CASE DIGEST : Superior General of the Religious of the Virgin Mary (R.V.M.) v. Republic of the Philippines G.R. No. 205641, October 5, 2022 GAERLAN

 

FACTS

The Superior General of the Religious of the Virgin Mary (R.V.M.), a religious corporation sole engaged in operating Catholic educational institutions, filed an application for the judicial confirmation and registration of title over a 4,539-square-meter parcel of land in Borongan, Eastern Samar. R.V.M. claimed that it and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession of the property since 1946 under a bona fide claim of ownership. The RTC granted the application, but the Court of Appeals reversed, holding that R.V.M., as a corporation sole, was constitutionally disqualified from acquiring alienable lands of the public domain and that it failed to sufficiently prove the land's alienable and disposable status.

Before the Supreme Court, R.V.M. argued that it had complied with the requirements for judicial confirmation of imperfect title under Section 48(b) of Commonwealth Act No. 141 (Public Land Act), as amended by Republic Act No. 11573, which now requires proof of at least 20 years of open, continuous, exclusive, and notorious possession immediately preceding the application. The Court also examined Section 14 of Presidential Decree No. 1529 (Property Registration Decree), as amended by R.A. No. 11573, and the constitutional limitation under Section 3, Article XII of the 1987 Constitution, which prohibits private corporations from acquiring alienable lands of the public domain except by lease.

ISSUE

Whether R.V.M., a religious corporation sole, is qualified to acquire ownership of alienable lands of the public domain through judicial confirmation of imperfect title under Section 48(b) of the Public Land Act, notwithstanding the constitutional prohibition under Section 3, Article XII of the 1987 Constitution against private corporations acquiring alienable public lands except by lease.

Whether R.V.M. sufficiently established all the requisites for registration of title, particularly the alienable and disposable character of the land as required under R.A. No. 11573, and the required period and nature of possession by itself and its predecessors-in-interest to warrant judicial confirmation of title.

HELD

The Supreme Court granted the petition and remanded the case to the Court of Appeals for further proceedings. It clarified that under R.A. No. 11573, an applicant for judicial confirmation of imperfect title must prove that the land has been declared alienable and disposable and that the applicant or its predecessors-in-interest possessed it openly, continuously, exclusively, and notoriously for at least twenty (20) years immediately preceding the application. However, the Court found that the records were insufficient to conclusively determine the land's classification and the exact extent of the property acquired by R.V.M.'s predecessors, making a remand necessary for the reception of additional evidence and a resurvey of the property.

The Court also reaffirmed the doctrine in Republic v. Villanueva that religious corporations, whether organized as a corporation sole or corporation aggregate, remain private corporations within the contemplation of Section 3, Article XII of the Constitution. Consequently, they cannot acquire alienable lands of the public domain through judicial confirmation of imperfect title, as this mode of acquisition is reserved to qualified Filipino citizens or those expressly authorized by law. The constitutional prohibition aims to prevent the concentration of public lands in corporate entities and to promote equitable land distribution. Nevertheless, the Court held that a remand was still proper to determine which portions of the property, if any, were privately acquired rather than derived from the public domain, and to ascertain compliance with the requirements of R.A. No. 11573 before resolving the application for registration.