GR L 3015; (January, 1908) (Digest)
G.R. No. L-3015
January 23, 1908
THE ROMAN CATHOLIC APOSTOLIC CHURCH, ET AL., plaintiffs, vs. CERTAIN MUNICIPALITIES IN THE PROVINCE OF ORIENTAL NEGROS, ET AL., defendants.
FACTS:
The Roman Catholic Apostolic Church, et al. (plaintiffs) filed an original action before the Supreme Court, as provided by Act No. 1376 , against Certain Municipalities in the Province of Oriental Negros, et al. (defendants), specifically mentioning Gregorio Aglipay and the municipalities of Ayuquitan, Dumaguete, Bais, and Tayasan. The plaintiffs sought to recover various properties.
Among the properties claimed were:
1. A portion of land in the municipality of Ayuquitan, described as “occupied by the church and convent,” but also noted as “planted with sixteen cocoanut trees.”
2. A tract of land in Dumaguete (formerly Sibulan), initially described as “whereon the church and convent of Sibulan are located,” but limited during the hearing to a specific portion.
Evidence showed that both the Ayuquitan land (coconut trees) and the specific portion of the Dumaguete land were used as agricultural lands for raising crops. There was no evidence presented that these lands were used in connection with any church, cemetery, or convent. The evidence regarding actual possession by either party was conflicting.
Section 1 of Act No. 1376 grants the Supreme Court original jurisdiction to “hear and finally determine all actions which involve controversies… as to the title to any and all churches, convents, or cemeteries in the Philippine Islands and real and personal property used in connection therewith, or as to the ownership, right of administration, or possession thereof.”
ISSUE:
Does the Supreme Court have original jurisdiction under Section 1 of Act No. 1376 to determine the title or possession of lands claimed by the Roman Catholic Apostolic Church that are primarily agricultural and not directly “used in connection with” a church, convent, or cemetery?
RULING:
No. The Supreme Court held that it does not have jurisdiction under Act No. 1376 to decide controversies over lands that are primarily agricultural and not directly used in connection with a church, convent, or cemetery.
The Court explicitly stated that its jurisdiction, as granted by Section 1 of Act No. 1376 , is limited to questions relating to a “church, a convent, or a cemetery, or to real or personal property used in connection therewith.” Since the lands in Ayuquitan and Dumaguete were found to be agricultural lands used for raising crops and there was no evidence linking them to the functions of a church, convent, or cemetery, they did not fall within the terms of the jurisdictional grant.
Therefore, the Court dismissed the action without costs as far as it related to the municipalities of Ayuquitan and Dumaguete regarding these specific properties. The Court made no determination as to the rights of the parties concerning these properties, as it lacked the statutory jurisdiction to do so.