G.R. No. L-12776; March 23, 1960
MARTIN AGLIPAY, ET AL., petitioners-appellees, vs. MONS. ISABELO DE LOS REYES, JR., as Obispo Maximo of the Iglesia Filipina Independiente, oppositor-appellant.

FACTS

On September 25, 1956, petitioners-appellees, all surnamed Aglipay and claiming to be heirs of the late Monsignor Gregorio Aglipay, filed a petition in the Court of First Instance of Ilocos Sur (Land Registration Case No. 93). They alleged that the deceased died intestate on September 1, 1940, leaving nine parcels of land in Santa Cruz, Ilocos Sur, covered by Transfer Certificate of Title No. 40. They further claimed that oppositor-appellant Monsignor Isabelo de los Reyes, Jr., as the incumbent Obispo Maximo of the Philippine Independent Church (Iglesia Filipina Independiente), was in possession of the duplicate certificate of title and had refused to surrender it despite demands. They prayed for an order under Section 111 of the Land Registration Act requiring the surrender of the title.
The oppositor-appellant, in his answer and opposition, alleged that the properties were owned by the “Iglesia Filipina Independiente” and were registered in the name of Monsignor Gregorio Aglipay only in his capacity as the then Supreme Bishop of the Church, or as a corporation sole. He stated that on May 17, 1956, he had registered an adverse claim on behalf of the Church under Section 110 of Act No. 496, that the Church had always been in possession and enjoyed the fruits of the properties, and that the petitioners were guilty of laches for waiting over 16 years to present their claim. Based on this, the oppositor filed a counter-petition for registration.
The lower court, after urging the parties to submit memoranda on whether it could order the surrender of the title under Section 111 despite the raised question of ownership, allowed the parties to present evidence. Thereafter, it rendered a decision denying both the petition and the counter-petition. The court found the opposition to be supported by good and valid reasons, and denied the counter-petition because the adverse claim was already annotated on the title and the serious questions of ownership involved were not within the province of a land registration court but should be litigated in an independent civil action. The oppositor appealed insofar as the judgment did not order the issuance of a new title in the name of the Iglesia Filipina Independiente.

ISSUE

Whether the trial court, acting as a land registration court, erred in refusing to decide the issue of ownership and in dismissing the counter-petition, thereby requiring the parties to resolve the ownership dispute in an independent civil action.

RULING

The Supreme Court affirmed the order of the lower court. The Court held that the lower court, acting as a land registration court, did not commit reversible error in abstaining from making a definite finding on ownership and in requiring the issue to be ventilated in an independent civil action.
The Court noted that the parties were allowed to present evidence merely to enable the court, acting as a land registration court, to rule intelligently on the propriety and merits of the petition and opposition. The lower court did not view the evidence as sufficient to fully apprise it of the ownership issue and enable a final settlement. It only decided that the opposition was not frivolous or vexatious, thus entitling the oppositor to prevent the summary relief sought by the petitioners.
The Supreme Court cited its ruling in Director of Lands vs. Register of Deeds that Section 112 of the Land Registration Act authorizes only alterations that do not impair recorded rights, or those consented to by all parties, or corrections of obvious mistakes. While there are exceptions where a land registration court may decide issues ordinarily litigable in ordinary civil actions—based on mutual consent or acquiescence of the parties, full opportunity to present evidence, and the court’s consideration that the evidence of record is sufficient—these conditions were not fully met here. The Court found that the trial judge did not abuse his discretion in determining that the evidence was not adequate for a final decision on ownership.
The Supreme Court concluded that the lower court’s preference for the ownership issue to be resolved in an independent civil action, thereby maintaining the status quo, was not improper under the circumstances, especially given the conflicting claims of the parties. Costs were imposed on the appellant.