Hacbang v. Director of Lands
REITERATIONFacts
The Antecedents: The Roman Catholic Bishop of the Diocese of Samar and Leyte applied for the registration of two parcels of land (lots Nos. 1 and 2) in Laoang, Samar. The Director of Lands and the Municipality of Laoang opposed, claiming portions of lot No. 1 and the entirety of lot No. 2 were public plazas. Evidence showed that the Roman Catholic Church, belfry, and convent were erected on lot No. 1 prior to 1869. A fire in 1869 damaged these structures, leading to provisional construction on lot No. 2 while reconstruction occurred on lot No. 1. Five years later, reconstruction on lot No. 1 was completed. Governor Pablo Galza ordered owners of nipa shacks east of lot No. 1 not to rebuild there, providing them with other land. Lot No. 2 had fourteen stone pillars representing the stations of the cross, used for the Way of the Cross celebration. Nine pillars remain, with stumps of the others visible. Lot No. 2 was also used as a cemetery and, provisionally, for a municipal building and school after the American occupation in 1902. A Rizal monument was later erected by the municipality on lot No. 2. Procedural History: The trial court ordered the registration of lot No. 1, except for the eastern portion claimed by the oppositors, in favor of the applicant. It declared the eastern portion of lot No. 1 and the entire lot No. 2 as public plazas. The applicant appealed. The Petition: The applicant-appellant sought the registration of both lots, asserting ownership based on donations and continuous possession under claim of ownership.
Issue(s)
Whether the eastern portion of lot No. 1 and the entire lot No. 2 belong to the Roman Catholic Apostolic Church. Whether the possession of the church, even without documentary proof of donation, is sufficient to establish ownership. Whether the erection of public buildings and a monument on lot No. 2, and the use of portions of lot No. 1 by residents, interrupted the church's possession or divested its ownership.
Ruling
The appealed judgment is reversed. Lots Nos. 1 and 2, with their improvements (except the Rizal monument), are ordered to be registered in the name of the applicant and appellant, the Roman Catholic Bishop of the Diocese of Samar and Leyte.
Ratio Decidendi
On whether the eastern portion of lot No. 1 and the entire lot No. 2 belong to the Roman Catholic Apostolic Church: The Court found that the evidence indisputably established that these lands belonged to the Roman Catholic Apostolic Church. The church had been in possession of these lands, along with the church, belfry, and convent, for over half a century. The presence of the Catholic cemetery on lot No. 2 and the erection of stone posts and pillars for the Way of the Cross conclusively proved the church's ownership and its constant claim of ownership over the property. The Court cited several previous decisions affirming the property rights of the Catholic Church in similar circumstances. On whether the possession of the church, even without documentary proof of donation, is sufficient to establish ownership: The applicant's theory of acquisition through donations, though lacking documentary evidence, was deemed unnecessary given the long-standing, public, open, and continuous possession under claim of ownership for over half a century. The Court reasoned that since the alleged donations took place long before the Civil Code, documentary proof was not essential, especially when ownership and right of possession could be demonstrated through such possession. Alternatively, the Court presumed that if donations did not exist, the portion formed part of the lands assigned to the church for religious structures and cemetery, which are necessary for the practice of the Catholic religion. On whether the erection of public buildings and a monument on lot No. 2, and the use of portions of lot No. 1 by residents, interrupted the church's possession or divested its ownership: The Court held that acts of possession exercised through tolerance or permission, such as residents rebuilding houses on lot No. 1 after being prohibited by Governor Galza, do not serve to acquire possessory title or title of ownership, citing Articles 444 and 447 of the Civil Code. Similarly, the provisional erection of a public school and a municipal building on lot No. 2 did not conflict with the church's possession, especially since lot No. 2 was not designated for these purposes according to the Laws of the Indies and was dedicated to religious cult. The protest and subsequent detainer action filed by the church against the construction of the Rizal monument demonstrated its exercise of rights to prevent an attempt against its property, and the decision in the detainer case did not constitute res judicata in the registration case, nor did it deprive the church of its ownership rights.
Main Doctrine
The Roman Catholic Apostolic Church's continuous, public, and adverse possession of lands, even without documentary proof of donation, can establish ownership, especially when such possession is coupled with the erection of religious structures and the use of the land for religious purposes, and acts of tolerance by the owner do not interrupt possession for acquisitive prescription.