GR L 2352; (July, 1910) (Digest)
G.R. No. L-2352
ELADIO ALONSO, plaintiff-appellee, vs. TOMAS VILLAMOR, ET AL., defendants-appellants.
July 26, 1910
FACTS:
The defendants, members of the municipal board of Placer, took possession of a Roman Catholic church, its appurtenances (including the convent and cemetery), and contents from its priest, Eladio Alonso, in December 1901. They claimed municipal ownership, asserting that the church and its articles were built and purchased with funds voluntarily contributed by the people of the municipality, thereby belonging to the town. Padre Alonso protested but was summarily removed from possession. Alonso then filed an action to recover the value of the articles taken and the rental value of the church and its appurtenances for the period of illegal occupation. The lower court rendered judgment in favor of Alonso, awarding P1,581. The defendants appealed, reiterating their claim of ownership and arguing that Alonso was not the real party in interest.
ISSUE:
1. Was the Roman Catholic Church the rightful owner of the properties taken by the defendants, and were the defendants’ actions wrongful?
2. Can the Supreme Court substitute the real party in interest (the Roman Catholic Apostolic Church) as plaintiff, despite the action initially being brought by the priest, Eladio Alonso, who was not the real party in interest?
RULING:
1. Yes. The Supreme Court affirmed that the properties belonged to the Roman Catholic Church, citing previous rulings (e.g., Roman Catholic Apostolic Church vs. Municipality of Placer; Barlin vs. Ramirez), which had established the Church’s ownership of such properties. Consequently, the defendants’ seizure and occupation of the church and its contents were deemed wrongful and illegal. The Court also upheld the lower court’s assessment of the value of the articles taken and the rent for the illegal occupation.
2. Yes. The Court acknowledged that Eladio Alonso was not the real party in interest and that, under Section 114 of the Code of Civil Procedure, an action must be prosecuted in the name of the real party in interest (which was the Roman Catholic Apostolic Church or the Bishop of the diocese). However, the Court invoked Section 503 of the Code of Civil Procedure, which prohibits reversing judgments on technical grounds or for errors that have not prejudiced the real rights of the excepting party. The Court held that the error in naming Eladio Alonso as the plaintiff was purely technical, as he had clearly acted on behalf of the Church. The substitution of the Roman Catholic Apostolic Church as the party plaintiff was deemed a formal, not a substantial, amendment, as it merely made the form express the substance of the litigation without misleading anyone or prejudicing the defendants. The Court emphasized that litigation is not a game of technicalities but a pursuit of justice on the merits.
Therefore, the Supreme Court ordered the amendment of the process, pleadings, proceedings, and decision by substituting the Roman Catholic Apostolic Church in place of Eladio Alonso as the party plaintiff. As so amended, the decision of the lower court was affirmed.