Chapter 3 Where the land has been sold under pacto de retro, the

vendor a retro may file an application for the original

Ordinary Registration
registration of the land, provided, however, that should the
1. APPLICATIONS period of redemption expire during the pendency of the
registration proceedings and ownership to the property
Sec 14 Who may apply – the following persons may file in the consolidated in the vendee a retro, the latter shall be
proper RTC an application for registration of title of land, substituted for the applicant and may continue the
whether personally or through an authorized proceedings.
representatives:
A trustee on behalf of his principal may apply for original
1. Those who by themselves or through their predecessors – registration of any land held in trust by him, unless
in – interest have been in open, continuous, exclusive and prohibited by the instrument creating the trust.
notorious possession and occupation (OCENPO) of alienable
and disposable lands of the public domain under a bona fide Purpose of the Torrens System of Registration
claim of ownership since June 12, 1945, or earlier.
To decree land titles that shall be final, irrevocable and
2. Those who have acquired ownership of private lands by undisputable. INCONTENSTABILITIY IS THE GOAL including
prescription under the provisions of existing laws the national government and all the branches thereof.
Subject, however, to the right of any person deprived of land
3. Those who have acquired ownership of private lands or or of any estate or interest therein by such adjudication or
abandoned river beds by right of accession or accretion confirmation of title obtained by actual fraud to be filed in
under the existing laws. the proper RTC by way of petition for reopening and review
of the decree of registration not later than 1 year from and
4. those who have acquired ownership of land in any other
after the date of the entry of such decree of registration.
manner provided by law
A certificate of title is the best proof of ownership of land.
Where the land is owned in common, all the co – owners
The title, once registered, is notice to the world. All persons
shall file the application jointly.
must take notice. No one can plead ignorance of the
registration.
 Registration only confirms ownership Systems of Registration

Thus, a decree of registration merely confirms, but does not 2 systems of registration
confer ownership.
 For registered lands under PD No. 1529 (Property
The primary purpose of the Torrens system is the registration Registration Decree) and
of title not the acquisition of land and to relieve the land  For unregistered lands under Act. No. 3344
from unknown liens or claims, except those which shall be
Note: Registration of instrument must be done in the proper
noted in the order of registration and in the certificate
registry in order to bind the land.
issued. If there exist known and just claims against the title
of the applicant, he gains nothing in effect by his registration, Example: If a parcel of land covered by a Torrens title is sold,
except in the simplicity of subsequent transfers of his title. but the sale is registered under Act. No. 3344, the sale is not
considered registered and the registration of the deeds does
Registration does not vest or give title to the land, but
not operate as constructive notice to the whole world.
merely confirms and thereafter protects the title already
possessed by the owner, making it imprescriptible by For Act. No. 3344 its provides the system of recording of
occupation of 3rd parties. transactions over unregistered real estate without prejudice
to a 3rd party with a better right. There can be no
Placing a parcel of land under the Torrens system does not
constructive notice through registration under Act. 3344 if
mean that ownership can no longer be disputed. Ownership
the property is registered under Torrens system, nor can the
is different from a certificate of title.
registration be effective for purposes of Article 1544 of the
While certificate of title may be considered the best proof of Civil code on double sale.
ownership, the mere issuance thereof does not foreclose the
The recording of instruments relating to unregistered lands is
possibility that the property may be under co – ownership
governed by Section 113 of PD No. 1529 which provides that
with persons not named in the certificate or that the
no deed of conveyance, mortgage, lease affecting land not
registrant may only be a trustee or that other parties may
registered under Torrens system shall be valid, except as
have acquired interest subsequent to the issuance of the
between the parties, unless such instrument shall have been
certificate of title.
recorded in the office of the register of deeds. The recording,
however, shall be without prejudice to a 3 rd party with a on the basis of native title and defines the extent of these
better right. lands and domains.

Laws governing land registration Registration Proceedings are judicial and in rem

The state has control over the real property within its limits. Hence, a land registration court’s decision ordering the
The sale possess not only the right to determine how title to confirmation and registration of title being the result of a
real estate may be acquired and proved, but it is also within proceeding in rem, binds the whole world.
its legislative capacity to establish the method of procedure.
Note:
The primary sources of legislation governing the registration
 Action to recover real property are in personam
of private lands and lands of the public domain are
 Actions quasi in rem deal with status, ownership or
1. CA No. 141 (Public Land Act) - governs the judicial liability of a particular property but which are
confirmation of imperfect or incomplete titles on the basis of intended to operate only as between the particular
possession and occupation of alienable portions of the public parties to the proceedings. the judgement therein are
domain in the manner and for the length of time required by binding only upon the parties who joined in the
law. action.
 Registration under the Public Land Act, Property
2. PD 1529 (Property Registration Decree) – a codification of
Registration Decree and Indigenous Peoples Right Act
laws relative to the registration of property and supersedes
is VOLUNTARY, because it is the person claiming
all other laws relative to registration of property.
ownership who initiates the action, registration under
3. Act. 2259 (Cadastral Act) - aims to serve public interest by the Cadastral Act is COMPULSORY because it is the
requiring that the title to any lands be titled and adjudicated. government itself which initiates the petition.

4. RA 8371 (Indigenous Peoples Rights Act) – recognizes the Co – owners shall file application jointly
rights of ownership and possession of indigenous cultural
Under the Civil Code, each co - owner shall have the full
communities to their ancestral domains and ancestral lands
ownership of his part and the fruits and benefits pertaining
thereto, and he may therefore, alienate, assign or mortgage
it, except when personal rights are involved. BUT, the effect land, the name of registered owner and a reference to the
of the alienation or the mortgage, with respect to the co – number of the certificate of title. Such claim shall not affect
owners, shall be limited to the portion which is allotted to the title of a purchaser for value and in good faith before its
him in the division upon the termination of the co – registration.
ownership. Since a co – owner cannot be considered a true
Note: A corporation sole is not the owner of the properties
owner of a specific portion until division or partition is
that he may acquire but merely the administrator and holds
effected, he cannot file an application for registration for the
the same in trust for the members of the society for which
whole area without joining the co – owners as applicants.
the corporation is organized.
Vendee a retro may file application in his name

Pacto de Retro sale refers to the sale wherein the seller has
the right to repurchase the subject matter or the property
being [Link] essence of a pacto de retro sale is that the
title and ownership of the property sold transfers
immediately to the vendee a retro.

A sale with a pacto de retro transfers the legal title to the

vendee and the vendee is subrogated to all the rights and
actions of the vendor, subject to the latter’s right of
redemption. Having the legal title to the land, the vendee a
retro has a registrable title which may be the subject of
initial registration.

Trustee may apply for registration on behalf of his principal

Whoever claims an interest in registered land by reason of

any implied or constructive trust shall file with the register of
deeds a sworn statement containing the description of the
2. Registration under Section 14(1) already been declared alienable and disposable at the time
of the application for registration.
Section 14(1) of the Property Registration Decree pertains to
original registration through ordinary registration Land must already be ALIEANBLE and DISPOSABLE at the
proceedings. time of the filing of the application

The right to file the application for registration derives from Republic VS. Naguit – ISSUE: whether it is necessary under
a bona fide claim of ownership going back to June 12, 1945 Section 14(1) of the Property Registration Decree that the
or earlier, by reason of the claimant’s (OCENPO) of alienable subject land be first classified as alienable and disposable
and disposable lands of the public domain in the concept of before the applicant’s possession under a bona fide claim of
an owner without regard to whether the land was ownership could even start.
susceptible to private ownership at that time.
RULING: the Court answered in negative, holding that
Under Section 14 (1), it is required that: Section 14(1) merely requires the property sought to be
registered as already alienable and disposable at the time
1. the land applied for is an agricultural public land already
the application for registration of title is filed.
classified as alienable and disposable land at the time of the
filing of the application for registration Republic VS. Court of Appeals – the court noted that “to
prove that the land subject of an application for registration
2. the applicant or through his predecessors – in – interest,
is alienable, an applicant must establish the existence of a
has been in OCENPO of the land under a bona fide claim of
positive act of the government such as a presidential
ownership.
proclamation or an executive order; an administrative
3. Such possession and occupation must have commenced action; investigation reports of Bereau of Lands
since June 12, 1945 or earlier. investigators; and a legislative act or statute”

Note: the law does not imposes requirement that the land NOTE BENE: Section 14(1) requires that the property sought
should have been declared alienable and disposable to be registered be alienable and disposable at the time of
agricultural land as early as June 12, 1945. What is important the filing of the application for registration. A notation in a
in computing the period of possession is that the land has survey plan indicating that a parcel of land is inside the
alienable and disposable land of the public domain does not June 12, 1945. It is sufficient that the land is already declared
constitute a positive act of the government classifying the as alienable and disposable land at the time the application
land as such. Verily, a mere surveyor has no authority to for registration is filed so as to entitle the possessor to
reclassify lands of the public domain. registration. The reason behind this is that, if the state, at
the time the application is made, has not yet deemed it
Proof that land is alienable and disposable
proper to release the property for alienation or disposition,
Doctrine: to be subject of appropriation, the land must be the presumption is that the government is still reserving the
declared alienable and disposable either by the President or right to utilize the property.
the Secretary of the DENR.
Note: the Executive Department is vested with the authority
Applicants must present the following proof: to classify lands of the public domain, Property Registration
Decree, presupposes that the land subject of the application
 Copy of the original classification approved by the for registration must have been already classified as
DENR Secretary and certified as true copy by the legal agricultural land of the public domain in order for the
custodian of the records. provision to apply. Thus, absent proof that the land is
already classified as agricultural land, the Regalian doctrine
Note: For non – agricultural lands, like forest lands. There can
applies, and overcomes the presumption that the land is
be no imperfect title to be confirmed over lands not yet
alienable and disposable.
classified as disposable and alienable. To be disposable and
alienable, there must be a proclamation to that effect so that Note: Corporations may now acquire lands of the public
it may form part of the disposable agricultural lands of the domain for as long as the lands were already converted to
public domain. Forest lands cannot be alienated in favour of private ownership by operation of law.
private persons or entities. Possession of such cannot ripen
into ownership unless such lands are classified and To be clear, then, the requirement that the land should have
considered disposable and alienable lands. been classified as alienable and disposable agricultural land
at the time of the application for registration is necessary
Malabanan VS Republic – the law does not require that the only to dispute the presumption that the land is inalienable.
land subject of registration should have been alienable and
disposable during the entire period of possession, or since
 Classification according to ownership 1935 Constitution – lands of public domain were classified
into three (3) Agricultural, timber and mineral
Land, which is an immovable property, may be classified as
either 1973 Constitution – lands of the public domain were
classified into seven (7) agricultural, industrial or
 public dominion or
commercial, residential, resettlement, mineral, timber or
 private ownership
forest, and grazing land, with the reservation that the law
Land is considered of public dominion if: might provide other classification.

 intended for public use 1987 Constitution - it adopted the classification under the
 belongs to the state, without being for public use and 1935 constitution. Thus lands of the public domain were
is intended for some public service or for the classified into four (4) Agricultural, timber, mineral and
development of the national wealth. national parks.

Note: Land belonging to the state that is not characterized in Requisites character and period of possession and
the above statements or with such character but no longer occupation
intended for public use or public service forms part of the
The intent behind the use of “possession” in conjunction
patrimonial property of the state.
with “occupation” is to emphasize the need for actual and
Land that is other than part of the patrimonial property of not just constructive or fictional possession.
the state, provinces, cities and municipalities is of private
The law speaks of possession and occupation. Since these
ownership if it belongs to a private individual.
words are separated by the conjunction “and”, the clear
Classification according to alienability intentional of the law is not to make one synonymous with
the other.
Whether or not land of the public domain is alienable and
disposable primarily rests on the classification of public lands Possession is broader than occupation because it includes
made under the constitution constructive possession.
Occupation, seeks to delimit the all-encompassing effect of  The possession and occupation must be OCENPO
constructive possession. The word occupation serves the  The possession and occupation must be under a bona
highlight the fact that for an applicant to qualify, his fide claim of acquisition of ownership
possession must not be a mere fiction, it must be actual  The possession and occupation must have taken place
possession. since June 12, 1945 or earlier; and
 The property subject of the application must be an
Note: Without satisfying the requisites character and period
agricultural land of the public domain.
of possession – possession and occupation that is OCENPO
since June 12, 1945 or earlier – the land cannot be Note: Public lands not shown to have been reclassified or
considered ipso jure converted to private property even released as alienable agricultural land or alienated to a
upon the subsequent declaration of it as alienable and private person by the state remain part of the alienable
disposable. public domain.

Prescription never began to run against the state, such that Registration under Section 14(2)
the land has remained ineligible for registration under
Properties of public dominion cannot be acquired by
Section 14(1) of the Property Registration Decree unless
prescription. No matter how long the possession of the
Congress enacts a law or the president issues a proclamation
properties has been, there can be no prescription against the
declaring the land as no longer intended for public service or
state regarding property of public domain. Even a city or
for the development of the national wealth.
municipality cannot acquire them by prescription as against
Summary of the requirements for registration under Section the state. The exception is where the law itself provides for
14(1) of PD No. 1529 it.

In the case of Malabanan VS. Republic, it sums up the Thus, patrimonial property of the state may be the subject of
requirements for registration acquisition through prescription

 The applicant, or through his predecessor – in – Section 14(2) of PD No. 1529 provides that the following may
interest, has been in possession and occupation of the apply for registration by prescription, whether personally or
property subject of the application. through their duly authorized representatives,
“(2) Those who have acquired ownership of private lands by prescription, unless otherwise provided. Property of the
prescription under the provisions of existing laws” state or any of its subdivisions not patrimonial in character
shall not be the object of prescription.
Question: Did the enactment of the Property Registration
Decree and the amendatory PD No. 1073 preclude the Acquisitive prescription of dominion and other real rights
application for registration of alienable lands of the public may be ordinary or extraordinary.
domain, possession over which commenced only after June
Ordinary acquisitive prescription requires possession of
12, 1945?
things in good faith and with just title for the time fixed by
A: No, In the case of Malabanan it did not, considering law.
Section 14(2) of the Decree which governs and authorizes the
Section 14(2) refers to the principles on prescription, as set
application of “those who have acquired ownership of
forth in the civil code. In this regard, the civil code makes it
private lands by prescription under the provisions of existing
clear that patrimonial property of the state may be acquired
laws” While as a rule, prescription does not run against the
by private persons through prescription. However, this does
state, the exception is where the law itself expressly
not neceesarily mean that when a piece of land is declared
provides for it. An example of which is Section 14(2) which
alienable and disposable, it can already be acquired by
allows qualified individuals to apply for the registration of
prescription. There must be an express declared that the
property, ownership of which he has acquired by
public dominion property was no longer intended for public
prescription under existing laws.
service or the development of the national wealth or that
Section 14(1) Section 14(2) the property had been converted into patrimonial.
Covers alienable and Covers private property
disposable lands Kinds of Prescription
Prescription is inapplicable Prescription is applicable
1. Ordinary acquisitive prescription – a person acquires
ownership of a patrimonial property through possession for
Prescription, generally at least 10 years, in good faith and with just title.

Article 1113 of the civil code provides that “all things which 2. Extraordinary acquisitive prescription – a person’s
are within the commerce of men are susceptible of uninterrupted adverse possession of patrimonial property
for at least 30 years, regardless of good faith or just title, When lands of the public domain become patrimonial
ripens into ownership pursuant to Article 1137 of the civil property of the state
code.
Remember: for acquisitive prescription to commence and
*good faith of the possessor consists in the reasonable belief operate against the state, the classification of land as
that the person from whom he received the thing was the alienable and disposable alone is not sufficient. The applicant
owner thereof, and could transmit his ownership. must be able to show that the state, in additional to the said
classification, expressly declared through either a law
Concept of possession for purposes of prescription
enacted by congress or a proclamation issued by the
In order to ripen into ownership, possession must in the president that the land is no longer retained for public
concept of owner, public, peaceful and uninterrupted. service or the development of the national wealth or that
the property has been converted into patrimonial.
Possession is…….
Thus, mere classification of the subject property does not
 Open – when it is patent, visible, apparent, notorious change its status as public dominion. There must be an
(not clandestine – secret) express declaration for the effect.
 Continuous – not interrupted, unbroken or occasional
 Exclusive – when the adverse possessor can show Lands of public dominion shall form part of the patrimonial
exclusive dominion over the land and an property of the sate when there is a declaration by the
appropriation of it to his own use and benefit government that these are:
 Notorious – when it is so conspicuous that is generally
 Alienable or disposable
known and talked of by the public or the people in
 No longer intended for public use or public service
the neighbourhood.
Only when such lands have become patrimonial can the
Note: Possession does not mean that a man has to have his
prescriptive period for the acquisition of property of the
feet on every square meter of property before it can be said
public dominion begin to run.
that he is in possession.
Thus, where the land is already a private land, the applicant
has the right to register the same even if the possession
thereof for the required prescriptive period commenced on a good faith and with just title, or for at least 30 years,
date later than June 12, 1945. regardless of good faith or just title; and
 The land already been converted or declared as
Summary: There must be an express declaration by the state
patrimonial property of the state at the beginning of
that the public dominion property is no longer intended for
the said 10 year or 30 year period of possession.
public service or the development of the national wealth or
that the property has been converted into patrimonial. *Acquisitive prescription could only run against private
Without such express declaration, the property, even if properties, which include patrimonial property of the state,
classified as alienable or disposable, remains property of the but never against public properties.
public dominion, pursuant to Article 420(2) and thus,
Section 14(1) Section 14(2)
incapable of acquisition by prescription. It is only when such
Refers to registration of title Entitles the applicant to the
alienable and disposable lands are expressly declared by the
on the basis of possession registration of his property
state to be no longer intended for public service or for the on the basis of prescription
development of the national wealth that the period of Registration is extended Registration is available both
acquisitive prescription can begin to run. under the aegis of PD 1529 under PD 1529 and Civil Code
and the Public Land Act
Such declaration shall be in the form of a law duly enacted by Covers alienable and Covers private property
Congress or a Presidential Proclamation in cases where the disposable land
President is duly authorized by law. Requires that the possession It is silent as to the required
and occupation required to nature of possession and
Espiritu VS. Republic – summarizes the requisites for acquire an imperfect title occupation; however, Article
registration under Section 14(2) of PD No. 1529 to prosper, over an alienable and 1118 of the civil code
to wit: disposable public land must requires that possession for
be OCENPO in character purposes of prescription
 The land is an alienable and disposable and must be in the concept of an
patrimonial property of the public domain owner, public, peaceful and
 The applicant and its predecessors – in – interest have uninterrupted.
been in possession of the land for at least 10 years, in
 Acts which do not constitute an effective interruption of alienable or disposable, remains property of the public
possession dominion. Thus, incapable of acquisition by prescription.

Mere notice of adverse claim do not constitute an effective Acquisition of private lands or abandoned river beds by right
interruption – Azardon – Crisologo VS. Ranon of accession or accretion under Section 14(3)

Acts of declaring again the property for tax purposes and Under Article 461 of the Civil Code, river beds which are
obtaining a Torrens Certificate of title in one’s name cannot abandoned through the natural change in the course of the
defeat another’s right of ownership acquired through waters ipso facto belong to the owner whose lands are
acquisitive prescription. occupied by the new course in proportion to the area lost.
However, the owners of the lands adjoining the old bed shall
A protest filed before an administrative agency and even the
have the right to acquire the same by paying the value
decision resulting from it cannot effectively toll the running
thereof, which value shall not exceed the value of the area
of the period of acquisitive prescription. (only in cases filed
occupied by the new bed.
before the courts may judicial summons be issued and thus
interrupt possession) Example: A and B each owns land on opposite sides of a
river. The river changed its course, passing through the land
Application of Section 14(2) as synthesized in Malabanan
of C.
case
Question: who owns the abandoned river bed?
Public domain lands become only patrimonial property not
Answer: C owns it, to compensate him for his loss.
only with a declaration that these are alienable or
Suppose that 2 owners, C and D, lost portions of their lands
disposable. There must also be an express government
Question: Who owns the river bed?
manifestation that the property is already patrimonial or no
Answer: C and D, in proportion to the area lost.
longer retained for public service or the development of the
national wealth and only when the property has become
The Requisites for the application of Article 461 are:
patrimonial can the prescriptive period for the acquisition of
 The change must be sudden in order that the old river
property of the public dominion begin to run. Without such
may be identified
express declaration, the property, even if classified as
  The changing of the course must be more or less There must be evidence to prove that the addition to the
permanent and not temporary overflooding of property was made gradually through the effects of the
another’s land current of the river. A riparian owner then does not acquire
 The change of the river must be a natural and not the addition to his land caused by special works expressly
artificial intended or designed to bring about accretion.
 There must be definite abandonment by the
government (if the government shortly after the Accretion does not automatically become registered land
change decided and actually steps to bring the river to
its old bed, Article 461 will not apply) Under Article 457 of the civil code, the registered owner of
property is considered the lawful owner of the accretion ot
Ownership by right of accretion along river banks his property, but the accretion does not become
automatically registered land just because the lot which
Requisites of accretion are the following receive it is covered by a torrens title thereby making the
 That the deposit be gradual and imperceptible; alluvial property imprescriptible. To bring an area formed by
 That it be made through the effects of the current of accretion under the torrens system, there must be an
the water; and application for registration filed for the purpose.
 That the land where accretion takes place is adjacent
to the bank of rivers
Where alluvial increment is not registered, it may be
acquired by 3rd persons through prescription
Note: In the absence of evidence that the change in the
course of the river was sudden or that it occurred through In order that the accretion may be protected by the rule on
avulsion, the presumption is that the change was gradual imprescriptibility, it is necessary that the same be brought
and caused by accretion and erosion. under the operation of the torrens system. Where the
adjoining land owners does not cause the registration of the
Alluvion must be the exclusive work of nature increment to his property, the same may be acquired by 3 rd
persons through prescription.
 Alluvial formation along the seashore forms part of the reservation are considered worthy of protection and are
public domain usually respected, but where the president, as authorized by
law, issues a proclamation reserving certain lands, and
In contrast to the rule on accretion, alluvial formation along
warning all persons to depart therefrom, this terminates any
the seashore is part of the public domain and therefore, not
rights previously acquired in such lands in order to obtain
open to acquisition by adverse possession by private
preferential right of purchase and patents for lands which
persons. It is outside the commerce of man, unless otherwise
have been previously granted, reserved from sale or
declared by either the executive or legislative branch of the
appropriated are void.
government.
Summary of rules relative to disposition of public land or
Dried – up river beds
lands of public domain
A dried – up river bed belongs to the state as property of
General Rule: Pursuant to regalia doctrine, all lands of the
public dominion, not to the riparian owner, unless a law
public domain belong to the state and are inalienable. Lands
vests the ownership in some other person.
that are not clearly under private ownership are also
Acquisition of ownership in any other manner provided for presumed to belong to the state and therefore, may not be
by law under Section14(4) alienated or disposed.

Section 14(4) refers to acquisition of ownership in any other Exemption: the following are exempted from the general
manner provided by law, which could either be a statute or rule
executive act.
 Agricultural lands of the public domain
Reservation for a specific public purpose by Presidential  Lands of the public domain subsequently classified or
Proclamation declared as no longer intended for public use or for
the development of the national wealth and are
Lands covered by reservation are not subject to entry, and no considered converted into patrimonial lands or lands
lawful settlement on them can be acquired. of private ownership that may be alienated or
The claims of persons who have settled on, occupied and disposed.
improved a parcel of public land which is later included in a
 Land acquisition by private corporation the constitutional limitation on acquisition by individual of
alienable lands of the public domain.
Private corporations or associations may not hold, such
alienable lands of the public domain except by lease, for a A corporation sole is qualified to apply for registration
period not exceeding 25 years, renewable for not more than
A corporation sole is qualified to own and register private
25 years and not to exceed 1000 hectares in area.
agricultural land.
Note: the rule then is that private corporations or
A corporation sole by the nature of its incorporation is
associations are disqualified from acquiring alienable lands
vested with right to purchase and hold real estate property
of the public domain. However, jurisprudence in the case of
because it is a special form of corporation usually associated
Suzi VS. Sazon provides that
with clergy. A corporation sole consists of one person only.
“where at the time the corporation acquired the land, its
A corporation sole is merely an administrator of the church
predecessors – in – interest had been in possession and
properties and not an owner and to transmit these
occupation thereof in the manner and for the period
properties to his successor in said office.
prescribed by law as to entitle him for registration in his
name, then the proscription against corporations acquiring Vested rights cannot be impaired by subsequent law
alienable lands of the public domain except through lease
does not apply for the land was no longer public land but The court stated that even the constitution or subsequent
private property. law cannot impair those vested right that was given prior to
the enactment of that law.
Purpose of Prohibition

To transfer ownership of only a limited area of alienable

lands of the public domain to a qualified individual. Without
the constitutional ban, individuals who already acquired the
maximum area of alienable lands of the public domain could
easily set up corporations to acquire more alienable public
lands. The corporation is a convenient vehicle to circumbent