Roman Catholic Apostolic Church v. Municipalities of Tarlac
REITERATIONFacts
The Antecedents: The Roman Catholic Apostolic Church (plaintiff) filed an original action against the Municipalities of Tarlac and Victoria, and Gregorio Aglipay, among others, seeking to be declared owner of certain described lands, including plazas, church grounds, and cemeteries. The plaintiff alleged ownership and possession of these lands for several years prior to the filing of the complaint. Procedural History: An amended complaint was filed, and an answer was submitted. A commissioner was appointed to take evidence. Subsequently, the plaintiffs and the Attorney-General, representing the defendant municipalities, entered into an agreement to dismiss the complaint concerning public highways and plazas. The dispute was narrowed to specific lands in the barrio of La Paz, municipality of Tarlac, namely the grounds of the old church, the old cemetery, and the new cemetery. The Petition: The plaintiff sought to be declared the owner of the property and for the defendants to have no right or interest therein. The defendants, in their answer, alleged that the property was public property belonging to the Government of the Philippine Islands, that the plaintiff's possession was merely for administration, and that its rights ceased with Spanish sovereignty. They also claimed the Independent Filipino Church took possession for administration. A motion to dismiss was filed by Gregorio Aglipay, arguing Act No. 1376 was void for violating the equal protection clause of the Act of Congress of July 1, 1902.
Issue(s)
Whether Act No. 1376 is void for violating the equal protection of the laws. Whether the Roman Catholic Apostolic Church is entitled to the possession of the church and cemetery grounds in the barrio of La Paz, municipality of Tarlac. Whether the property in question is public property belonging to the Government of the Philippine Islands.
Ruling
The Court adjudged and decreed that the Roman Catholic Apostolic Church is entitled to the immediate possession of the grounds of the old church of La Paz, the old cemetery of La Paz, and the new cemetery of La Paz, and that neither the municipality of Tarlac nor Gregorio Aglipay has any right, title, or interest therein. The defendants were ordered to be ousted from possession, and possession was awarded to the plaintiffs. A writ of possession was ordered to issue. The action was dismissed without costs as to other defendants. All property described in the complaint, except that relating to the La Paz property, was eliminated from the complaint, with no determination made regarding the rights of the parties to that eliminated property.
Ratio Decidendi
On the constitutionality of Act No. 1376: The Court held that Act No. 1376, which grants original jurisdiction to the Supreme Court for controversies concerning church property between the Roman Catholic Church and the Independent Filipino Church and municipalities, is constitutional. The argument that it discriminates against municipalities by requiring the Attorney-General's consent to commence actions was dismissed, drawing an analogy to a U.S. Supreme Court case where a similar procedural provision was upheld as a valid exercise of legislative power to provide a specific, efficient method of procedure. The Court found no violation of the equal protection of the laws or due process clauses. On the ownership and possession of the La Paz property: The Court applied the principles established in prior cases, such as Barlin vs. Ramirez, Roman Catholic Church vs. Santos, and City of Manila vs. The Roman Catholic Church. These cases held that the King of Spain was not the owner of such property, and title did not pass to the U.S. Government, nor did municipalities own such property. The evidence showed the plaintiff church had been in possession of the La Paz property for over twenty-five years, and the defendants presented no evidence of title or interest. The Court reiterated that a plaintiff in quiet and peaceful possession for a great number of years may recover possession from a defendant who shows no title, even without written evidence of ownership, citing Bishop of Cebu vs. Mangaron. On whether the property is public property: The Court rejected the defendants' claim that the property was public property belonging to the Government of the Philippine Islands. Applying the jurisprudence from previous cases, it was established that such church properties were not owned by the Spanish Crown and thus did not pass to the U.S. Government, nor were they municipal property. The possession by the plaintiff church for over twenty-five years, coupled with the defendants' failure to establish any right or title, led to the conclusion that the plaintiff was entitled to possession.
Main Doctrine
The Roman Catholic Apostolic Church is entitled to the immediate possession of church and cemetery grounds that it has possessed for more than twenty-five years, even without written evidence of ownership, where the defendants show no title or interest therein. Laws providing specific procedures for certain controversies, such as Act No. 1376, are constitutional if they provide a valid and constitutional exercise of legislative power and do not violate fundamental rights.