GR L 11955; (July, 1918) (Digest)
G.R. No. L-11955; July 29, 1918
THE GOVERNMENT OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. MARTIN AVILA, ET AL., opponents; THE ROMAN CATHOLIC ARCHBISHOP OF MANILA, appellant.
FACTS:
Cadastral proceedings were instituted to determine ownership of various lots in Cavite. Lot No. 389 was claimed by the Archicofradia del Santisimo y Animas del Purgatorio de Cavite and by the Roman Catholic Archbishop of Manila. Lots Nos. 584-A, 637, 751-A, 761, and 762 were claimed by the Cofradia de Jesus Nazareno of San Roque and also by the Archbishop. It was undisputed that these religious associations had been in possession of the lots for many decades through donations. The Cofradia de Jesus Nazareno was organized under Spanish laws (Law 25, Title IV of the Laws of the Indies and Royal Cedula of 1805), with its bylaws approved by Royal Order in 1895. The Archicofradia, however, was not proven to have been legally constituted under the former regime. The Court of First Instance decreed registration of the lots (except improvements) in favor of the Cofradia de Jesus Nazareno and the members of the Archicofradia, and denied the petition of the Roman Catholic Archbishop of Manila. The Archbishop appealed.
ISSUE:
Whether the registration of the disputed lots should be decreed in the name of the religious associations (Cofradia de Jesus Nazareno and Archicofradia) or in the name of the Roman Catholic Archbishop of Manila as a sole corporation.
RULING:
The Supreme Court affirmed the lower court’s decision with modifications.
1. For Lots Nos. 584-A, 637, 751-A, 761, and 762: Registration was ordered in favor of the Cofradia de Jesus Nazareno. The Court held that this Cofradia, though not incorporated under the present Corporation Law ( Act No. 1459 ), was a legally existing Catholic association organized under Spanish law. As such, it qualified as a juridical entity entitled to own property and register titles under Section 19, No. 5 of the Land Registration Act ( Act No. 496 ). The Archbishop’s mere right of supervision over the Cofradia did not equate to ownership of its properties.
The Court emphasized that the Torrens system requires registration only in favor of proven owners with proper juridical personality. The Archbishop’s motion for reconsideration and new trial was subsequently denied in a Resolution dated November 9, 1918.