Register of Deeds of Rizal v. Ung Siu Si Temple
REITERATIONFacts
The Antecedents: Jesus Dy, a Filipino citizen, executed a deed of donation on January 22, 1953, conveying a parcel of residential land in Caloocan, Rizal, to the unregistered religious organization "Ung Siu Si Temple." The donation was accepted by Yu Juan, the founder and deaconess of the Temple, who is of Chinese nationality, acting on behalf of the Temple and its trustees, who are also all Chinese citizens. Procedural History: The Register of Deeds of Rizal refused to accept the deed for record. This refusal was elevated en consulta to the Court of First Instance of Manila, which upheld the Register of Deeds' action. The Court ruled that the acquisition of land by the Temple was prohibited by Sections 1 and 5 of Article XIII of the Constitution, citing the case of Krivenko vs. the Register of Deeds of Manila. The Petition: The donee, Ung Siu Si Temple, appealed the ruling, arguing that its acquisition of land for religious purposes was authorized by Act No. 271 of the Philippine Commission and that the refusal violated the freedom of religion clause of the Constitution.
Issue(s)
Whether Act No. 271 of the Philippine Commission, which permits religious associations to hold land, remains valid in light of the 1935 Constitution. Whether the prohibition against the acquisition of land by foreign nationals or corporations not meeting the ownership requirements extends to religious organizations. Whether the constitutional prohibition on land acquisition by foreign nationals violates the freedom of religion.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, upholding the refusal to register the deed of donation. The Court ruled that the provisions of Act No. 271 were deemed repealed by the Constitution insofar as they were incompatible with its absolute terms regarding land ownership.
Ratio Decidendi
On the validity of Act No. 271: The Court held that the provisions of Act No. 271 of the Philippine Commission were deemed repealed by the Constitution of the Philippines, particularly Sections 1 and 5 of Article XIII, in so far as they were incompatible with the Constitution's absolute terms. The Constitution explicitly states that "Save in cases of hereditary succession, no private agricultural land shall be transferred or assigned except to individuals, corporations or associations qualified to acquire or hold lands of the public domain in the Philippines." This provision makes no exception in favor of religious associations, nor do Sections 1 and 2 of Article XIII, which restrict the acquisition of public agricultural lands and other natural resources to "corporations or associations at least sixty per centum of the capital of which is owned by such citizens" of the Philippines. Therefore, any prior law allowing religious associations to hold land, if incompatible with these constitutional provisions, is considered repealed. On the applicability of constitutional prohibition to religious organizations: The Court clarified that the constitutional inhibition against the acquisition of land by foreign nationals or corporations not meeting the ownership requirements applies to religious organizations. The fact that the appellant religious organization had no capital stock did not exempt it from the constitutional prohibition, as it was admitted that its members were of foreign nationality. The Court emphasized that the purpose of the sixty per centum requirement is to ensure that corporations or associations allowed to acquire agricultural land or exploit natural resources are controlled by Filipinos. In the absence of capital stock, the controlling membership must be composed of Filipino citizens. To permit religious associations controlled by non-Filipinos to acquire agricultural lands would revive alien religious land holdings, which was a historical grievance that contributed to the revolution of 1896. On the violation of freedom of religion: The Court was not convinced that the disqualification under Article XIII violated the freedom of religion guaranteed by Article III of the Constitution. It was not shown that land tenure was indispensable to the free exercise and enjoyment of religious profession or worship, or that one could not worship the Deity according to the dictates of conscience unless upon land held in fee simple. The constitutional limitations on land ownership were deemed distinct from the right to religious freedom.
Main Doctrine
Religious organizations whose members are predominantly foreign nationals cannot acquire land in the Philippines, even for religious purposes, as such acquisition is prohibited by the Constitution, which implicitly repealed prior laws allowing such ownership.