MANILA ELECTRIC COMPANY vs.

JUDGE FLORELIANA CASTRO-BARTOLOME 114 SCRA 799 DATE: June 29, 1982 PETITIONER: Manila Electric Company RESPONDENTS: Court of First Instance of Rizal, Makati Branch XV and Republic of the Philippines PONENTE: J. Aquino FACTS: The Manila Electric Company purchased two lots (165 sqm.) with an assessed value of P3270 in Tanay, Rizal from the Piguing spouses on August 13, 1976, who had consequently purchased it from Olympia Ramos on the 3rd of July 1947, the original owner of the land even before 1941. They consequently filed for the confirmation of title on Dec. 1, 1976, a motion that was rejected by the Court of First Instance. The Meralco consequently filed an appeal with the following contentions: 1. The land after having been possessed by Olimpia Ramos and the Piguing spouses for more than thirty years had essentially been converted to private land by virtue of acquisitive prescription. Thus, the constitutional prohibition banning a private corporation from acquiring alienable public land is not applicable. 2. It had invoked section 48b 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 ISSUES: 1. Whether or not the Meralco, as a juridical person, is qualified to apply for a judicial confirmation of an imperfect/incomplete title. 2. Whether or not the conversion of the land in question is recognized. 3. Whether or not the conversion of the land from public to private property is contingent on the judicial confirmation of title. RULING: 1. NO. According to Sec. 48b of the Public Lands Act, the Meralco, as a juridical person, is disqualified from applying for the judicial confirmation of imperfect title. Furthermore, according to J. Aquino, Article XIV Sec. 14 of the 1973 Constitution prohibits private corporations from hold alienable lands of the public domain except by lease, not to exceed 1000 hectares in area. In fine, only natural persons and citizens of the Philippines are allowed to apply for confirmation under the PLA. 2. NO. It was held that the conversion from public land to private property is contingent upon (1) fulfilling the necessary condition of possession by

the predecessors-in-interest for the statutory period of 30 years; and (2) the judicial confirmation of the title by the Court of First Instance. C.J. Fernando concurred with the decision, but accepted that a conversion indeed took place. 3. HELD. This was maintained in the ruling of J. Aquino. C.J. Fernando, J. Abad Santos and J. De Castro, concurred accordingly. J. Teehankee dissented and traced the line of jurisprudence from Carino to Susi to Herico which maintained that the conversion or acquisition effectively happens by the operation of law, ipso jure, as soon as it can be conclusively presumed, juris et de jure, that all the conditions for the confirmation of the grant have been met. According to his reasoning, upon the fulfillment of the aforementioned conditions, the confirmation of an imperfect title is only a formality. NOTES: