Roman Catholic Apostolic Administrator of Davao, Inc. v. Land Registration Commission
REITERATIONFacts
1. The Antecedents: Mateo L. Rodis executed a deed of sale for a parcel of land in Davao City to the Roman Catholic Apostolic Administrator of Davao, Inc. The Register of Deeds of Davao City, referencing a prior court resolution concerning another religious corporation, required the Administrator to submit an affidavit confirming that at least 60% of its members were Filipino citizens, as a condition for registering the deed of sale. The Administrator expressed willingness to provide an affidavit but argued that the Carmelite Nuns case was dissimilar due to differences in corporate structure and ownership principles. 2. Procedural History: The Register of Deeds, entertaining doubts about the registerability of the deed, referred the matter to the Land Registration Commissioner for resolution. After a hearing, the Commissioner issued a resolution on September 21, 1954, holding that the Roman Catholic Apostolic Administrator of Davao, Inc. was not qualified to acquire private lands in the Philippines without proof that at least 60% of its capital, property, or assets were owned or controlled by Filipino citizens, citing constitutional provisions. The Commissioner ordered the Register of Deeds to deny registration. Following the denial of a motion for reconsideration, the Roman Catholic Apostolic Administrator of Davao, Inc. filed a petition for mandamus with the Supreme Court. 3. The Petition: The petitioner, the Roman Catholic Apostolic Administrator of Davao, Inc., seeks a writ of mandamus to compel the registration of the deed of sale. It argues that under the Corporation Law and established jurisprudence, the deed of sale is effectively in favor of the Catholic Church, which is qualified to acquire private agricultural lands for religious purposes. The petitioner contends that the constitutional requirement of 60% Filipino ownership or control is either inapplicable to corporations sole, which are mere administrators of church properties held in trust for the faithful, or that this requirement is met by the predominantly Filipino composition of the Catholic population and clergy in Davao. The petition also invokes the Supreme Court's procedural rule for appeals from administrative bodies, specifically Rule 43.
Issue(s)
Whether a corporation sole, whose incumbent head is an alien, is disqualified under the 1935 Constitution from acquiring and registering private agricultural lands in the Philippines.
Ruling
The Supreme Court reversed the resolution of the Land Registration Commissioner. It ordered the respondent Register of Deeds of Davao City to register the deed of sale executed by Mateo L. Rodis in favor of the Roman Catholic Apostolic Administrator of Davao, Inc.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that a corporation sole is not the owner of the properties it acquires but merely the administrator thereof, holding them in trust for the church or religious society. Applying Sections 154, 157, and 163 of Act No. 1459 (Corporation Law), the Court emphasized that temporalities are held for the "sole benefit of his religious denomination," and ownership logically devolves upon the church or congregation. In this case, the Catholic population of Davao is predominantly Filipino, thereby satisfying the spirit of the 1935 Constitution's nationality requirements as established in Register of Deeds of Rizal v. Ung Sui Si Temple. The Court further reasoned that a corporation sole has no nationality and its status is not altered by the change of citizenship of the incumbent, as it is a legal fiction created for perpetuity and the transmission of property to successors. The 60% capital requirement in Article XIII, Section 1 was intended to prevent foreign economic penetration and conserve natural resources, but it does not apply to corporations sole which are non-stock entities and lack 'capital' to be divided into percentages. Finally, the Court noted that the power of a corporation sole to purchase land for religious or charitable purposes under Section 159 of the Corporation Law was not repealed by the Constitution, as the framers—predominantly Catholic—could not have intended to curtail the propagation of faith and the necessary expansion of places of worship and schools.
Main Doctrine
A corporation sole, such as the Roman Catholic Apostolic Administrator of Davao, Inc., is not disqualified from acquiring private agricultural lands in the Philippines, as it is considered a juridical entity with no nationality, and its ownership of properties is merely for administration in trust for the benefit of the faithful, irrespective of the nationality of its incumbent.