Meralco vs Castro Bartolome Digest

June 8, 2013 G.R. No. L-49623 June 29, 1982 MANILA ELECTRIC COMPANY, petitioner-appellant, vs. JUDGE FLORENLIANA CASTRO-BARTOLOME of the Court of First Instance of Rizal, Makati Branch XV, and REPUBLIC OF THE PHILIPPINES, respondent-appellees. The Manila Electric Company purchased two lots (165 sqm.) at Tanay, Rizal on August 13, 1976 from Piguing spouses. After acquisition, they subsequently filed for judicial confirmation of imperfect title on Dec. 1, 1976. However, the court denied the petition and the corresponding appeal was likewise rejected. It elevates its appeal with the following arguments; firstly, the land in question had essentially been converted to private land by virtue of acquisitive prescription as a result of open continuous and notorious possession and occupation for more than thirty years by the original owner, Olimpia Ramos and his predecessor in interest, Piguing spouses, whom Meralco acquired the disputed land, and finally, the substantial rights acquired by Ramos spouses and Peguing spouses for judicial confirmation of imperfect title, extend to Meralco by virtue of the provision of the Public Land Law. ISSUE: 1. Whether or not Meralco as a juridical person, allowed under the law to hold 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 and title of the land. 3. Whether or not 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 hold land of public domain. Article XIV Sec. 14 of the 1973 Constitution prohibits private corporations from holding alienable lands of the public domain except for lease of lands not exceeding one thousand hectares. 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 or by grant, belong to the public domain. The exception to the rule is only when the occupant and his predecessors-in-interest

possess and occupied the same since time immemorial. Such possessions justify the presumption that the land had never been part of the public domain or that it had been a private property even before the Spanish conquest. 3. Yes. In this case, the court declared that it is contingent upon the issuance of title before juridical entity may have acquired possession over the property. That means that until the certificate of title is issued, a piece of land, over which an imperfect title is sought to be confirmed, remains public land. Thus, any levy and execution were void. As between the State and the Meralco, the land in question remains a public land. The court also took notice that the constitutional prohibition makes no distinction between (on one hand) alienable agricultural public lands as to which no occupant has an imperfect title and (on the other hand) alienable lands of the public domain as to which an occupant has an imperfect title subject to judicial confirmation. Since section 11 of Article XIV does not distinguish, we should not make any distinction or qualification.