G.R. No. 30242 , March 25, 1929
THE ROMAN CATHOLIC ARCHBISHOP OF MANILA, plaintiff-appellee, vs. ALVARA FAJARDO and ERIBERTO NAVARRO, defendants-appellants.

FACTS

The Roman Catholic Archbishop of Manila filed an action for replevin to recover a venerated religious image known as “Santo Entierro” or “Apung Macalulu” and its carriage from the defendants, Alvara Fajardo and her agent Eriberto Navarro. The image was sculpted around 80-100 years prior by Buenaventura upon the order of then-parish priest of Angeles, Pampanga, Macario Paras. Church records from 1854 and 1865 indicated that the image and carriage were gifts from Padre Paras to the church. The image was kept in the church from about 1872 until it was forcibly taken by the defendants after a Holy Week procession in 1928. Alvara Fajardo claimed ownership, asserting title derived from Padre Paras’s universal heir, Mariano V. Henson, through subsequent transfers. Fajardo also held the office of “recamadera,” responsible for the image’s upkeep and the collection of alms for its religious services.

ISSUE

Whether the defendants have a valid claim of ownership over the religious image and carriage, thereby justifying their refusal to deliver the same to the plaintiff.

RULING

No. The Supreme Court ruled in favor of the plaintiff, the Roman Catholic Archbishop of Manila. The church records constituted evidence that Padre Paras had donated the image to the church during his lifetime. Consequently, the image did not form part of his estate that passed to his heir, Mariano Henson. Any subsequent transfers from Henson could not convey valid title. The defendant Alvara Fajardo’s rights as “recamadera” pertained only to the duties of maintenance and collection of alms, not to ownership. The church had held possession of the image under a claim of ownership for a long period. Therefore, the plaintiff’s title was perfected. The Court ordered the defendants to deliver the image and carriage to the plaintiff.