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Land Titles and Deeds Case Digest: Director of Lands v.

IAC (1986)
G.R. No. 73002 December 29, 1986
Lessons Applicable: Sec. 3 Art. XII, 1987 Constitution (Land Titles and Deeds)

FACTS:
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 landdates 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 when the Municipal Officials of Maconacon, Isabela
donated part of the land as the townsite of Maconacon Isabela
IAC affirmed CFI: in favor of
ISSUES:

1. W/N the land is already a private land - YES


2. W/N the constitutional prohibition against their acquisition by private corporations or associations applies- NO

HELD: IAC affirmed Acme Plywood & Veneer Co., Inc

1. YES

already acquired, by operation of law not only a right to a grant, but a grant of the Government, for it is not
necessary that a certificate of title should be issued in order that said grant may be sanctioned by the courts,
an application therefore is sufficient
it had already ceased to be of the public domain and had become private property, at least by
presumption
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
2. NO
If it is accepted-as it must be-that the land was already private land to which the Infiels had a legally
sufficient and transferable title on October 29, 1962 when Acme acquired it from said owners, it must also be
conceded that Acme had a perfect right to make such acquisition
The only limitation then extant was that corporations could not acquire, hold or lease public agricultural
lands in excess of 1,024 hectares

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