GR L 3007; (March, 1908) (Digest)
FACTS:
THE ROMAN CATHOLIC APOSTOLIC CHURCH, ET AL., plaintiffs, vs. THE MUNICIPALITY OF BADOC, ET AL., defendants. G.R. No. L-3007. March 30, 1908.
The Roman Catholic Apostolic Church (plaintiff) initiated an action against several municipalities of Ilocos Norte, Don Gregorio Aglipay (Obispo Maximo of the Independent Philippine Church), and other individuals, demanding the restitution of various properties.
The plaintiff asserted that from time immemorial, churches, conventos, cemeteries, and other properties associated with them in the towns of Badoc, Paoay, Pasuquin, San Miguel de Sarratt, Batac, Piddig, Dingras, Bacarra, Bangui, Laoag, Solsona, Vintar, Banna, and Nagpartian had been dedicated to the practice of the Roman Catholic religion. However, a few years prior to the complaint, the defendants unlawfully took possession of these properties and dedicated them to the use of the Independent Philippine Church.
The complaint detailed specific properties in each town, including churches, conventos, churchyards, towers, bells, cemeteries, altars, images, sacred cups, and other religious paraphernalia. Testimonies from municipal officials and even some “adverse” (Aglipayan) parish priests confirmed the historical dedication of these properties to the Catholic Church until around 1901-1902 when they were taken over by the municipalities or Aglipayan clergy. The defendants, particularly municipal presidents and Aglipayan curates, claimed that the buildings belonged to the Government and that previous Catholic curates administered them because they received salaries from the Government.
The court noted that certain parcels of land or building lots claimed in the complaint, which were not described as adjuncts to the religious buildings, were eliminated from the suit as they were considered outside the court’s original jurisdiction in this type of action.
ISSUE:
Who has the rightful claim and right to possession over the churches, conventos, cemeteries, and other religious properties that were historically dedicated to the Roman Catholic religion but were subsequently occupied by the Independent Philippine Church and local municipalities?
RULING:
The Supreme Court ruled in favor of The Roman Catholic Apostolic Church.
The Court ordered the immediate restitution of all contested churches, conventos, cemeteries, churchyards, towers, and religious paraphernalia to the plaintiff church, or its representative, in each of the named municipalities. The decision emphasized that these properties belonged to the Roman Catholic Church “by reason of the purposes to which they were devoted,” acknowledging their historical dedication and use for the Roman Catholic religion.
Writ of possession was ordered to be issued against Gregorio Aglipay, the specific Aglipayan priests administering the properties in each town, and the respective municipalities. The defendants in each pueblo and municipality were also sentenced to pay the costs.
Properties identified as mere building lots or parcels of land not adjuncts to the religious buildings were consistently eliminated from the restitution order, as they were deemed to be without the original jurisdiction of the court for this particular type of action.
