GR L 2264; (September, 1907) (Digest)
G.R. No. L‑2264
September 28 1907
FACTS
- P. Jose Evangelista (plaintiff) was the Roman‑Catholic parish priest of Laoag, Ilocos Norte. In October 1902 he formally broke from the Roman Catholic Church and joined the Independent Filipino Church, proclaiming himself its pastor.
- He left Laoag for Manila and, on 28 February 1903, delivered possession of the parish church and its adjoining property to his former coadjutor, P. Roman Ver (defendant).
- Ver was subsequently appointed permanent curate of the parish by the Roman‑Catholic bishop (30 March 1903) and acted as its priest while Evangelista was absent.
- The justice of the peace held that Ver held the premises only as a private agent of Evangelista and must return them on demand; the Court of First Instance reversed, granting possession to Ver.
ISSUE
Whether the defendant, having received possession of the parish property from the plaintiff who had by then abandoned the Roman Catholic Church, is legally bound under civil law to return the property to the plaintiff, notwithstanding the defendant’s alleged ecclesiastical allegiance and the differing rules of the two churches.
RULING
The Supreme Court reversed the Court of First Instance. It held that the relationship between Evangelista and Ver, for purposes of the civil action, is analogous to a private bailment/contractual entrustment: Ver’s only right to possession derived from Evangelista’s delivery and was subject to the condition of return on demand. The civil doctrine that a tenant (or agent) cannot defeat the title of the party who delivered possession applies regardless of the parties’ religious affiliations. Consequently, Ver is estopped from asserting an adverse title and must surrender the church premises to Evangelista.
Decision: Judgment reversed; plaintiff‑appellant’s right to possession affirmed.
