TL;DR

The Supreme Court ruled against Herederos de Ciriaco Chunaco Disteleria Incorporada (HCCDI), a corporation, denying their application to register land. The Court clarified that while the land in question was indeed alienable and disposable public land, HCCDI failed to prove continuous possession since June 12, 1945, a requirement for land registration based on possession. Crucially, the decision underscored that under the 1973 Constitution, which was in effect when HCCDI acquired the land, private corporations were prohibited from acquiring alienable public land, thus barring HCCDI from land ownership through registration.

Corporate Land Grab: When a Distillery’s Claim Runs Dry

Can a corporation acquire ownership of public land simply by claiming long-term possession? This case revolves around Herederos de Ciriaco Chunaco Disteleria Incorporada (HCCDI), a distillery company seeking to register a large plot of land in Albay. HCCDI argued they and their predecessors had been in continuous possession since 1945, entitling them to ownership. However, the Republic of the Philippines challenged this claim, questioning whether the land was truly alienable public land and whether HCCDI, as a corporation, could even own such land under the Constitution.

The legal battle hinged on two key requirements for land registration: first, the land must be classified as alienable and disposable public land; and second, the applicant must demonstrate open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier. The Court delved into the evidence presented by HCCDI to support their claim. Crucially, HCCDI relied on a Land Management Office report stating the land was alienable and disposable since 1926. They also presented testimonies and tax declarations dating back to 1980 to prove possession. However, the Republic argued that HCCDI needed to present the DENR Secretary’s original classification of the land and that the possession evidence was insufficient to reach back to 1945.

The Supreme Court acknowledged that HCCDI had substantially proven the land’s alienable and disposable nature, particularly because the lower court’s decision predated stricter evidentiary requirements set in a later Supreme Court case. The Court gave weight to the Land Investigator’s report and the lack of significant opposition from other government agencies on the land classification issue. This demonstrated a degree of flexibility from the Court, acknowledging the procedural timeline of the case.

However, the Court found HCCDI’s claim of possession wanting. While tax declarations can indicate possession, the earliest one presented by HCCDI was from 1980. This contradicted their claim of possession since 1945 through their predecessors-in-interest, the Heirs of Chunaco. The Court emphasized that continuous possession must be unequivocally proven, and sporadic tax declarations starting only in 1980 were insufficient. This highlighted the importance of robust and consistent evidence to substantiate claims of long-term possession for land registration.

Even more critically, the Supreme Court addressed the constitutional prohibition against corporate land ownership of public domain lands. The 1973 Constitution, in effect when HCCDI acquired the land in 1976, explicitly forbade private corporations from owning alienable public lands. Although the 1935 Constitution had allowed corporate ownership, the shift in 1973 created a significant barrier. The Court clarified that unlike a previous case involving land acquired from indigenous groups before 1973, in HCCDI’s situation, the land was still public when they acquired it. Therefore, the constitutional restriction applied directly, disqualifying HCCDI from registering the land regardless of possession claims.

This ruling reinforces the principle that corporations face constitutional limitations in acquiring public land through registration. It underscores the necessity for applicants to not only prove the alienable and disposable nature of the land and continuous possession but also to ensure they are legally qualified to own land under the prevailing constitutional framework at the time of acquisition. The case serves as a clear reminder of the enduring Regalian Doctrine in the Philippines, where the State owns all lands of the public domain unless proven otherwise, and the specific constraints placed on corporate land ownership.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Republic vs. Herederos de Ciriaco Chunaco Disteleria Inc., G.R No. 200863, October 14, 2020