Manila v. Roman Catholic Church
REITERATIONFacts
The Antecedents: The City of Manila filed an application for the registration of a parcel of land situated in the district of Paco, with an area of 16,412 square meters. Procedural History: The Roman Catholic Church objected to the application, asserting that the parcel was occupied by the church, convent, and cemetery of Paco since approximately 1801 until 1899. During this period, the church and convent were destroyed by the United States Army. The Church claimed the applicant was aware of their exclusive right of possession and that they had paid taxes on the property to the City of Manila. The Petition: The City of Manila sought to register the land. The Court of Land Registration admitted that the land was where the church and convent of Paco had stood since the beginning of the last century until 1899, when they were destroyed during the war. It was also admitted that the plot was part of a larger area granted by the Spanish Government to the inhabitants of Dilao or Paco for the establishment of their church. The Court of Land Registration sustained the objection of the Roman Catholic Church and denied the registration application.
Issue(s)
Whether the destruction of the church and convent on the land extinguishes the Roman Catholic Church's right of possession over the soil. Whether the City of Manila's application for land registration should be granted.
Ruling
The objection offered by the Roman Catholic Church is sustained. The registration applied for by the attorney for the City of Manila is hereby denied without costs.
Ratio Decidendi
On the issue of whether the destruction of the church and convent extinguishes the right of possession: The Court held that the destruction and disappearance of what was once constructed on the land is not a means for extinguishing real rights, particularly the right of possession. This principle applies in the absence of any legal provision or covenant that provides for such extinguishment, the existence of which was not alleged in this case. The Court emphasized that the right of possession held by the possessors over the soil prior to the destruction of the buildings remained intact. The affirmation by the appellant that residents permitted or tolerated the construction due to a duty to contribute towards the erection of their church was deemed gratuitous and without foundation. Therefore, the destruction of the physical structures did not negate the underlying possessory right over the land itself. On the issue of whether the City of Manila's application for land registration should be granted: The Court denied the application for registration. Based on the admitted facts and the established principles regarding real rights and possession, the Roman Catholic Church's objection was sustained. The Court found that the Church had maintained possession of the land since approximately 1801 until 1899, and the destruction of the church and convent did not extinguish their possessory rights. Consequently, the City of Manila failed to establish a registrable title to the land against the existing possessory rights of the Church.
Main Doctrine
The destruction or disappearance of buildings or structures on a parcel of land does not extinguish the real right of possession over the soil, absent any legal provision or covenant to that effect.