G.R. No. L-31286, March 10, 1930
THE ROMAN CATHOLIC BISHOP OF JARO, applicant-appellee, vs. THE DIRECTOR OF LANDS, opponent-appellant.

FACTS

The Roman Catholic Bishop of Jaro applied for the registration of four parcels of land in Sibalom, Antique. The Director of Lands opposed the registration of Lot No. 3, claiming it belonged to the public domain as part of the municipal plaza. The trial court granted the application and ordered the registration of all lots, including Lot No. 3, in favor of the applicant. The Director of Lands appealed, arguing that the applicant failed to prove ownership or possession sufficient for prescription, and that Lot No. 3 formed part of the public square.

ISSUE

Whether the Roman Catholic Bishop of Jaro has a registrable title over Lot No. 3, notwithstanding the claim that it is part of the public domain.

RULING

Yes. The Supreme Court affirmed the trial court’s decision, holding that the applicant had acquired ownership through long and continuous possession. The Court interpreted a prior 1908 decision (G.R. No. 3074) involving the same parties, which adjudged the Church entitled to possession of the Sibalom church, convent, and “the land occupied by these two buildings.” Following jurisprudence (Director of Lands vs. Aboc and Seminary of San Carlos vs. Municipality of Cebu), the phrase “land occupied” was construed to include not only the ground beneath the structures but also the adjacent land forming a single parcel bounded by streets. The Court also noted that under the Leyes de Indias, which governed town founding during the Spanish regime, churches were allotted land separate from the plaza, supporting the applicant’s claim without need for a written title. The applicant’s possession was deemed sufficient for prescription under Section 45(b) of Act No. 2874.