G.R. No. L-14793; April 28, 1961
PHILIPPINE INDEPENDENT CHURCH represented by HILARIO S. ZUMEL, petitioner, vs. JUANA MATEO and ISIDRO G. OLANO, respondents.

FACTS

The Philippine Independent Church (PIC), through Hilarion S. Zumel, filed a petition to review a land registration decree, alleging that respondent Isidro G. Olano, a former parish priest and trustee of church properties, fraudulently registered Lot No. 748 in his and his wife’s names. The petition was filed within the one-year period for review. During proceedings, respondents questioned Zumel’s authority, prompting court-ordered amendments to specify that he represented the “Fonacier faction” of the PIC. Subsequently, the Supreme Court ruled in another case that Isabelo de los Reyes, Jr., was the lawful head of the PIC.
More than two years later, respondents moved to dismiss, arguing that the PIC faction represented by Zumel (Fonacier) lacked legal capacity to sue since the lawful head was de los Reyes. Zumel opposed, contending the church itself was the real party-in-interest and that he had subsequently obtained a special power of attorney from de los Reyes to represent the PIC in the case. The trial court granted the motion to dismiss, holding that the amendments made after the one-year period took the petition out of the jurisdictional period and that a separate ordinary action was the proper remedy.

ISSUE

Whether the trial court erred in dismissing the petition for review of the land registration decree on the grounds of lack of legal capacity to sue and for being filed out of the reglementary period due to the amendments.

RULING

Yes, the trial court erred. The Supreme Court reversed the dismissal. On the issue of legal capacity, the Court held that the true petitioner is the Philippine Independent Church itself, the alleged owner of the disputed property. The designation of its representative’s factional affiliation is not controlling. The church, as a juridical entity, retains its interest in the property regardless of internal leadership disputes. The subsequent authority given by the lawful head, de los Reyes, to Zumel ratified his representation and sufficiently vested the petition with the requisite legal personality under Section 38 of the Land Registration Act.
On the issue of the amendments taking the petition out of the one-year period, the Court ruled that amendments relate back to the date of the original filing if the claim arises from the same transaction or occurrence. The original petition, filed timely, asserted the church’s ownership and the alleged fraud. The court-ordered amendments concerning representation were merely clarificatory and did not alter the fundamental claim. Therefore, the petition was deemed filed within the prescriptive period. The trial court’s suggestion to file a separate action would promote multiplicity of suits, which is discouraged. The case was remanded for further proceedings on the merits.