Roman Catholic Bishop of Tuguegarao v. Municipal of Aparri
REITERATIONFacts
The Antecedents: The Roman Catholic Bishop of Tuguegarao sought to register a parcel of land in Aparri. The municipality of Aparri opposed, claiming ownership through adverse possession for over ten years. The land was formerly occupied by a Catholic church. In 1898, revolutionary forces ejected the curate and turned the property over to municipal authorities. Ignacio Alvarado paid rent to the municipality from 1899 until 1904, after which the municipality took possession and used it as a landing place for a municipal ferry, collecting tolls. The Church declared the lot as its property during the first real property assessment and, in 1903 or 1904, demanded its return, but the municipality remained in possession. Procedural History: The Court of First Instance of Cagayan denied the registration, finding that the municipality had acquired title by prescription under section 41 of the Code of Civil Procedure due to adverse possession for more than ten years. The Petition: The Roman Catholic Bishop of Tuguegarao appealed the decision denying its right to have the land registered in its name.
Issue(s)
Whether the municipality of Aparri acquired title to the disputed lot by acquisitive prescription. Whether the municipality can acquire title to property by prescription against the Church, even if the property was previously privately owned.
Ruling
The Supreme Court affirmed the decision of the lower court, denying the registration of the land in the name of the Roman Catholic Bishop of Tuguegarao and upholding the title of the municipality of Aparri acquired by prescription. The motion for reconsideration was denied.
Ratio Decidendi
On the issue of acquisitive prescription by the municipality: The Court held that acquisitive prescription is a lawful source of title, and a municipality can acquire property by this means to the same extent as any other entity. The parcel in question had been continuously used as a wharf or landing place for a municipal ferry for more than the period required to confer title by prescription. Therefore, the legal title vested in the municipality, and the property is held by it in the character of patrimonial estate. The Court emphasized that this case was between the municipality and the Church, not between the municipality and the Insular Government. On the issue of acquiring title against the Church: The Court distinguished this case from prior rulings where municipalities were denied registration of public lands against the opposition of the Director of Lands. In those cases, the property was considered part of the Sovereign's domain, and mere occupation did not grant title by prescription against the State. However, in the present case, it affirmatively appeared that the parcel in question ceased to be part of the public domain and acquired the character of privately owned property more than a hundred years prior to the filing of the registration petition. Therefore, the Church, assuming it was the prior owner, lost the property by prescription due to the municipality's adverse possession.
Main Doctrine
A municipality can acquire property by acquisitive prescription to the same extent as any other entity, and if the property is used for a legitimate municipal purpose and held as patrimonial estate, title vests in the municipality. This is distinct from cases where a municipality claims title to public land by prescription against the Sovereign, which is not permitted.