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CASE DIGESTS
Republic v. Villanueva
June 29, 1982
Garcia, J.
Gabe Ruaro
SUMMARY:
The INC bought land, and wanted to have it registered. The
CFI and the SC agreed that it could not own land, as it is a
private corporation.
DOCTRINE:
A corporation sole, a juridical person, is disqualified to
acquire or hold alienable lands of the public domain, in
accordance with the constitutional prohibition in Section
11, Art. XIV of the 1973 Consti that no private corporation
or association ma hold alienable lands of the public domain
except by lease not to exceed one thousand hectares in
area.
Further a church is not entitled to avail itself of the
benefits of Section 48(b) which only applies to Filipino
citizens or natural persons. A corporation sole, an unhappy
freak of English law, has no nationality.
Teehankee, dissent:
The lands had already become private by the time the INC
acquired them. Thus, the consti. Prohibition against private
corporations owning public land no longer applies.
FACTS:
Lots nos. 568 and 569 in Barrio Dampol, Plaridel Bulacan,
with an area of 313 sqm were acquired by Iglesia ni Cristo in
exchange for a lot with an area of 247 sqm. The said lands
are in an area certified as alienable or disposable by the
Bureau of Forestry, nad have santol, mango, and banana
trees planted on them. The taxes covering them had been
paid.
The INC, a corporation sole, thus filed an application
for the registration of the two lots, alleging that it and its