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it had already ceased to be of the public domain and had become private
Land Titles And Deeds Case Digest:

property, at least by presumption
The application for confirmation is mere formality, the lack of which
Director Of Lands V. IAC (1986) 
does not affect the legal sufficiency of the title as would be evidenced
by the patent and the Torrens title to be issued upon the strength of said
G.R. No. 73002 December 29, 1986 patent.
 The effect of the proof, wherever made, was not to confer title, but
Lessons Applicable: Sec. 3 Art. XII, 1987 Constitution (Land Titles and Deeds) simply to establish it, as already conferred by the decree, if not by
FACTS: earlier law
 Acme Plywood & Veneer Co., Inc., a corp. represented by Mr. Rodolfo 2. NO
Nazario, acquired from Mariano and Acer Infiel, members of the  If it is accepted-as it must be-that the land was already private land to
Dumagat tribe 5 parcels of land which the Infiels had a legally sufficient and transferable title on
 possession of the Infiels over the landdates back before the Philippines October 29, 1962 when Acme acquired it from said owners, it must also
was discovered by Magellan be conceded that Acme had a perfect right to make such acquisition
 land sought to be registered is a private land pursuant to RA 3872  The only limitation then extant was that corporations could not acquire,
granting absolute ownership to members of the non-Christian Tribes on hold or lease public agricultural lands in excess of 1,024 hectares
land occupied by them or their ancestral lands, whether with the
alienable or disposable public land or within the public domain
 Acme Plywood & Veneer Co. Inc., has introduced more than P45M
worth of improvements
 ownership and possession of the land sought to be registered was duly
recognized by the government when the Municipal Officials of
Maconacon, Isabela
 donated part of the land as the townsite of Maconacon Isabela
 IAC affirmed CFI: in favor of
ISSUES:
1. W/N the land is already a private land - YES
2. W/N the constitutional prohibition against their acquisition by private
corporations or associations applies- NO
HELD: IAC affirmed Acme Plywood & Veneer Co., Inc
1. YES
 already acquired, by operation of law not only a right to a grant, but a
grant of the Government, for it is not necessary that a certificate of title
should be issued in order that said grant may be sanctioned by the
courts, an application therefore is sufficient