G.R. No. L-61145 – 212 Phil. 637 – 127 SCRA 687 – Mercantile Law – Corporation Law – Corporations are not Filipino Citizens
In 1955 and 1973, the Iglesia ni Cristo (INC) purchased two parcels of land in Camarines Norte. In 1976, INC filed an application for confirmation of title over said parcels of land. The Director of Lands opposed said application on the ground that these parcels of land are part of the public land. The trial court ruled in favor of INC.
ISSUE: Whether or not the Iglesia ni Cristo may register land under its name.
HELD: No. Under the Public Land Law, only Filipino citizens are entitled to register alienable public lands. A corporation, even a corporation sole like the INC (solely incorporated by one man, Eraño Manalo, a Filipino citizen), is disqualified from registering public land under its name. It can only hold alienable public land through lease. It cannot even register said lands under its name as a trustee.
NOTE: 60% rule: Corporations and Partnerships of which at least 60% of their capital belong to Filipinos may acquire real property.
