Roman Catholic Apostolic Church v. Municipalities of Caloocan
REITERATIONFacts
The Antecedents: The Roman Catholic Apostolic Church (plaintiff) filed an action to recover possession of various properties, including cemeteries and visitas, located in the municipalities of Caloocan, Morong, and Malabon. These properties were alleged to be in the possession and administration of the defendant municipalities and Gregorio Aglipay, among others. Procedural History: The defendants filed an answer, interposing a general and special denial. Defenses included claims that the properties were part of the public domain, that the Iglesia Filipina Independiente took possession by virtue of an Insular Government circular, and that the plaintiff church lacked civil personality to own bienes parroquiales constructed during the Spanish government. Some defendants appeared and answered, while others did not. Testimony was presented by the plaintiff and some defendants. No proof was offered for properties in Caloocan and for the church and cemetery in Novaliches, Malabon. The Petition: The plaintiff prayed for a decree that the properties belong to the Roman Catholic Apostolic Church, for the defendants to release and deliver the properties, for the appointment of a receiver, and for an injunction prohibiting the use of the properties for the Iglesia Filipina Independiente.
Issue(s)
Whether the Roman Catholic Apostolic Church is entitled to the possession and ownership of the properties in question. Whether the defendants have any right or interest in the said properties.
Ruling
The Court ruled in favor of the plaintiff, the Roman Catholic Apostolic Church, granting its prayer for possession and ownership of specific properties. A writ of possession was ordered to be issued against the defendants found in possession of these properties.
Ratio Decidendi
On the right of possession and ownership of the Roman Catholic Apostolic Church: The evidence disclosed, beyond peradventure of doubt, that the plaintiff had been in the quiet and peaceable possession of the different parcels of property, with reference to which evidence was presented, for a period immemorial, until some time between the years 1896-1899, when they were molested in their possession and deprived of the same by some of the defendants. The Court reiterated its previous decisions holding that where a person has been in long possession of real property and has been deprived thereof, he may recover it against one in possession, unless the latter can show a better right thereto. The Court also cited the decision of the Supreme Court of the United States in Municipality of Ponce v. Roman Catholic Apostolic Church, which held that the church had not only a right to the possession of its church edifices but was the lawful owner of the same. Furthermore, in The Roman Catholic Apostolic Church, et al. v. The Municipality of Placer, this Court followed the US Supreme Court's decision, holding that under the Spanish law and the Treaty of Paris, the Roman Catholic Apostolic Church is the owner of church buildings, convents, and cemeteries, and municipalities have no right of ownership therein by reason of funds or lands contributed for their foundation or erection. The Court noted the historical cooperation between the Crown of Spain and the Pope in extending the benefits of the Roman Catholic Apostolic Church, with the Government lending support, even to the extent of using public funds for the erection of churches. While the Crown reserved control, the intention was that such lands and edifices would be devoted absolutely to the use of the church. The long occupancy of properties for two to three hundred years without protest indicated an intention to transfer all rights and interests. Under the Treaty of Paris, the United States Government obligated itself to protect such interests. Therefore, the plaintiff was found entitled to the right of possession and ownership of specific visitas and cemeteries. On the legal questions presented by the answer of the defendant: The Court stated that the legal questions relating to the capacity of the Roman Catholic Apostolic Church to maintain the action and the constitutionality of Act No. 1376 had already been decided in several preceding decisions, and the arguments therein were made a part of the present decision. Thus, the prayer of the plaintiff's petition was granted.
Main Doctrine
The Roman Catholic Apostolic Church has the right of possession and ownership over church edifices, convents, and cemeteries, and municipalities have no right of ownership therein by reason of funds or lands contributed for their foundation or erection, especially when the Church has been in quiet and peaceable possession for time immemorial.