Meralco v.

Castro-Bartolome 114 SCRA 799

G.R. No. L-49623 June 29, 1982

FACTS:
Manila Electric Company, a domestic corporation organized under Philippine laws, more than
sixty percent of whose capital stock is owned by Filipino citizens, in its application filed on December 1,
1976 prayed for the confirmation of its title to two lots with a total area of one hundred sixty-five square
meters located at Tanay, Rizal acquired from Piguing spouses on August 13, 1976. Piguing spouses
bought the land from Olympia Ramos who possessed it since Pacific war. The land was declared for
realty tax purposes since 1945 and had been paid thereon up to 1977.
The Republic of the Philippines opposed the application on the grounds that the applicant, as a
private corporation,is disqualified to hold alienable public lands and that the applicant and its
predecessors-in-interest have not been in the open, continuous, exclusive and notorious possession
and occupation of the land for at least thirty years immediately preceding the filing of the
application.The lower rendered a decision dismissing the application because in its opinion the Meralco
is not qualified to apply for the registration of the said land since under section 48(b) of the Public Land
Law only Filipino citizens or natural persons can apply for judicial confirmation of their imperfect titles
to public land.
Meralco contends that the said land after having been possessed in the concept of owner by
Olimpia Ramos and the Piguing spouses for more than thirty years, had become private land and,
therefore, the constitutional prohibition, banning a private corporation from acquiring alienable public
land, is not applicable. It has invoke section 48(b) of the Public Land Law, not for itself, but for the
Piguing spouses who, as Filipino citizens, could secure a judicial confirmation of their imperfect title to
the land.

ISSUE:
(1)W/N Meralco is allowed under the Law to acquire lands of public domain and apply for judicial
confirmation of imperfect title.
(2)Does the possession tacked to predecessor private corporation automatically guarantee its
rights to possession of the land.
(3)W/N it is contingent for a judicial confirmation of title before any grant would be extended
to a juridical person?

RULING:
(1)No. Private corporation or juridical person is prohibited and not allowed under the law to
acquire lands of public domain.
(2)No. The presumption that since they bought the property from the person who occupied the
land in open, continuous, and notorious possession of the public land for more than thirty years,does
not automatically amount to rights and possession. It would cease to be public only upon the issuance
of the certificate of Title to any Filipino citizen claiming it under the law. This conclusion is anchored on
the principle that,”all Lands that were not acquired from the Government either by purchase,grant, or
homestead shall belong to the public domain. The exception to the rule is only when the occupant and
his predecessor-in-interest possessed and occupied the same since time immemorial. In which case, it
justifies the presumption that the land had never been part of the public domain or had been a private
property even before the Spanish government.
(3)Yes. In this case, the court declared that is is contingent upon the issuance of title before a
juridical entity may acquire possession over a property. It simply means that until the certificate of title
is issued, a piece of land, over which an imperfect title is sought to be confirmed remains a part of public
land. As between the State and the Meralco, the said land is still public land. Any levy and execution
were void. Section 11 of Article XIV makes no distinction between alienable agricultural public lands as
to which no occupant has an imperfect title and alienable lands of the public domain as to which an
occupant has an imperfect title subject to judicial confirmation, thus we should not make any distinction
or qualification
Mary Ann P. Poral