THE DIRECTOR OF LANDS v CA & IGLESIA NI CRISTO then it had acquired a vested right thereto, which the 1973

ed a vested right thereto, which the 1973 Constitution can

G.R. No. L-56613 March 14, 1988 neither impair nor defeat. Private respondent could have its title thereto
FERNAN, J.: confirmed through the appropriate proceedings as under the Constitution then in
force, private corporations or associations were not prohibited from acquiring
FACTS: public lands, but merely prohibited from acquiring, holding or leasing such type of
In 1973, private respondent INC filed an application with the CFI of Cavite for a land in excess of 1,024 hectares.
parcel of land with an area of 379sqm. RP, represented by DoL, opposed the
application. CFI rendered decision in favor of INC. DoL appealed contending that
the land was not properly identified because the original tracing cloth plan was
not submitted. CA affirmed CFI in toto.

ISSUE:
1. WON submission of the original tracing cloth plan is mandatory in land
registration proceedings.
2. WON the prohibition of acquisition by juridical entities under the 1973
Constitution is applicable in the instant case.

HELD:
1. NO. True certified copy of the white paper plan, was sufficient for the purpose
of Identifying the land in question. It was approved by the LRC and re-verified by
the Bureau of lands (now LMB). It contained all the details and information
necessary (location, area, land as plotted, technical descriptions and natural
boundaries) for a proper and definite Identification of the land sought to be
registered, thereby serving the purpose for which the original tracing cloth plan is
required and as such, the probative value is not affected.

Director of lands v. Reyes, 68 SCRA 177 is different it involves a vast tract of land
while in the instant case, it merely involves a comparatively small size of 379sqm
which is more readily Identifiable by reason of its location.

2. NO. Alienable public land held by a possessor, personally or through his

predecessors-in-interest, openly, continuously and exclusively for the prescribed
statutory period [30 years under the Public Land Act, as amended] is converted to
private property by mere lapse or completion of said period, ipso jure. The land
was acquired by INC from Aquelina in 1947 who in turn acquired the same from
Ramos siblings in 1936. The 30-year period of OCENPO was completed in 1966. At
this point, the land in question ceased by operation of law to be part of the public
domain. If in 1966, private respondent could have its title to the land confirmed,