G.R. No. L-9198; August 29, 1914
THE ROMAN CATHOLIC BISHOP OF LIPA, plaintiff-appellee, vs. THE MUNICIPALITY OF SAN JOSE, BATANGAS, defendant-appellant.

FACTS:
The Roman Catholic Bishop of Lipa filed an action for recovery of possession against the Municipality of San Jose, Batangas, over two parcels of land known as “the lands of the Virgin.” The plaintiff alleged ownership in fee simple, claiming the lands were donated to the Confraternity of the Lady of Consolation and were historically administered by the parish priests of San Jose. The plaintiff was forced to abandon the lands due to the disturbances of the Philippine Revolution, after which the defendant municipality took possession. The plaintiff presented as evidence two certificates of possessory information, duly recorded in the property registry, to support its claim. The defendant municipality, while occupying the lands, failed to present any title or evidence to justify its possession.

ISSUE:
Whether the plaintiff, the Roman Catholic Bishop of Lipa, has a better right to the possession and ownership of the two parcels of land than the defendant Municipality of San Jose.

RULING:
The Supreme Court affirmed the lower court’s decision in favor of the plaintiff. The Court held:
1. The possessory information titles presented by the plaintiff, being inscribed in the property registry, constitute prima facie proof of ownership, especially in the absence of any superior title presented by the defendant.

3. The forced abandonment of the lands by the church’s representatives due to the revolution did not result in the loss of its right of possession, as such abandonment was caused by force majeure. Acts done by force do not affect the right of the lawful possessor.
4. The Confraternity of the Lady of Consolation is a juridical entity capable of acquiring property. The lands, having been donated to the confraternity and administered by the church, are property dedicated to religious purposes.
5. Applying Spanish law and jurisprudence, property devoted to the service of God (such as for the support of Catholic worship) becomes incapable of private ownership and is held by the clergy as trustees. If the specific purpose fails, the property does not revert to the donor but devolves to the church.
Therefore, the plaintiff is entitled to the restitution of the lands. The decision ordering the defendant municipality to restore and deliver the lands to the plaintiff was affirmed.