G.R. No. L-4736
JEREMIAH J. HARTY, plaintiff-appellant, vs. FRANCISCO SANDIN, ET AL., defendants-appellants.
October 15, 1908

FACTS: On November 4, 1891, the Spanish Government granted a patent over four parcels of land, part of the hacienda of Nuestra Señora de la Guia. The patent identified Don Pablo Zamora y del Corro, curate and rector of the parish of the Sagrario, as the administrator of these lands, and stated that he should be regarded as the lawful owner as administrator. The Court determined that the true owner of the property was the Parroquia del Sagrario de la Catedral de Manila, which had existed since 1587 and had possessed the land since the early eighteenth century.

This action was commenced by Mgr. Jeremiah J. Harty, metropolitan archbishop of the Roman Catholic Apostolic Church of Manila, against numerous defendants (including Francisco Sandin) to eject them from the premises and declare ownership. The complaint alleged that Archbishop Harty was the archbishop and administrator of the property of the Roman Catholic Apostolic Church of the diocese of Manila, with the right to represent, administer, possess, and institute actions concerning the lands. It also stated that the Parish of the Sagrario was the absolute owner. The prayer sought a declaration that the hacienda was the sole and exclusive property of the Roman Catholic Apostolic Church of Intramuros and the ejectment of the defendants.

The lower court rendered judgment in favor of the plaintiff. The defendants appealed, having made no defense on the merits in the court below, only raising objections on appeal regarding the form of the action and the plaintiff’s personality. Specifically, they claimed: 1) the action was brought by Archbishop Harty as an individual; 2) the Roman Catholic Church is not a juridical person and cannot maintain actions without complying with corporation law; and 3) the archbishop could not maintain the action in his capacity as such, and it should have been brought in the name of the Church or the parish.

ISSUE: 1. Whether the action was improperly brought by Archbishop Harty as an individual.
2. Whether the Roman Catholic Church is a juridical person capable of maintaining an action in the Philippines without complying with corporation law.
3. Whether the Archbishop, in his capacity, can maintain an action relating to the property of a parish in his diocese, or if it must be brought in the name of the Church or the parish.

RULING: The Supreme Court affirmed the judgment of the court below, with costs against the appellants.

1. NO, the action was not brought by Archbishop Harty as an individual. The Court found that the allegations in the complaint clearly stated that Archbishop Harty was suing in his official capacity as the archbishop and administrator of the Roman Catholic Apostolic Church of the diocese of Manila, indicating his right to represent, administer, and possess the lands.

2. NO, the Roman Catholic Church is a juridical person capable of maintaining an action. The Court cited the Supreme Court of the United States case of Ponce v. The Roman Catholic Apostolic Church of Porto Rico and the Philippine case of Barlin v. Ramirez, which had already overruled this contention, establishing that the Roman Catholic Church possesses juridical personality and can maintain actions.

3. YES, the Archbishop can maintain the action in his capacity. The Court referred to the Ponce v. The Roman Catholic Apostolic Church of Porto Rico case, which involved a similar action brought by the Roman Catholic Church through its bishop. The Court also took judicial notice of Spanish law and institutions affecting the insular possessions. Furthermore, evidence showed that the archbishop was the supreme head of the church in his diocese and, in accordance with canonical law, possessed the right to maintain such an action relating to the property of a parish within his diocese.