Title
Aglipay vs. De Los Reyes, Jr.
Case
G.R. No. L-12776
Decision Date
Mar 23, 1960
Dispute over nine parcels of land in Santa Cruz, Ilocos Sur, between heirs of Monsignor Gregorio Aglipay and Iglesia Filipina Independiente. Ownership claims deemed outside land registration court's jurisdiction, requiring independent civil action.
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Case Digest (G.R. No. L-12776)

Facts:

Background of the Case:

  • The case involves a dispute over nine parcels of land located in Santa Cruz, Ilocos Sur, covered by Transfer Certificate of Title No. 40.
  • The petitioners-appellees, all surnamed Aglipay, are the heirs of the late Monsignor Gregorio Aglipay, who died intestate on September 1, 1940.
  • The oppositor-appellant, Monsignor Isabelo de los Reyes, Jr., is the incumbent Obispo Maximo of the Iglesia Filipina Independiente (Philippine Independent Church).

Petitioners' Claim:

  • The petitioners claimed that the lands were owned by Monsignor Gregorio Aglipay and that they, as his heirs, are entitled to the duplicate of Transfer Certificate of Title No. 40.
  • They alleged that Monsignor de los Reyes, Jr. is in possession of the title but refused to surrender it despite repeated demands.
  • They sought an order under Section 111 of the Land Registration Act to compel the surrender of the title.

Oppositor's Claim:

  • The oppositor, Monsignor de los Reyes, Jr., argued that the lands are owned by the Iglesia Filipina Independiente and were registered in Monsignor Gregorio Aglipay's name only in his capacity as the Supreme Bishop of the Church (a corporation sole).
  • He registered an adverse claim on behalf of the Church on May 17, 1956, under Section 110 of Act No. 496.
  • The oppositor asserted that the Church has always been in possession of the properties and enjoyed their fruits.
  • He also claimed that the petitioners were guilty of laches for waiting over 16 years to assert their claim.

Procedural History:

  • The lower court denied both the petition and the counter-petition, ruling that the issue of ownership should be resolved in an independent civil action.
  • The oppositor appealed, arguing that the trial court had jurisdiction to decide the ownership issue and that an independent civil action was unnecessary.

Issue:

  1. Jurisdiction of the Land Registration Court:

    • Whether the trial court, acting as a land registration court, had jurisdiction to decide the issue of ownership over the disputed properties.
  2. Propriety of an Independent Civil Action:

    • Whether the trial court erred in dismissing the petition and counter-petition and requiring the parties to resolve the ownership dispute in an independent civil action.
  3. Laches:

    • Whether the petitioners were guilty of laches for failing to assert their claim over the properties for more than 16 years.

Ruling:

The Supreme Court affirmed the decision of the lower court, holding that:

  • The trial court, acting as a land registration court, did not have jurisdiction to resolve the issue of ownership.
  • The issue of ownership should be litigated in an independent civil action.
  • The lower court did not abuse its discretion in abstaining from making a definitive ruling on ownership, given the conflicting claims and insufficient evidence.

Ratio:

  • (Unlock)

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